Introduction: Equity Crowdfunding Regulation in Turkey

Equity crowdfunding has become an increasingly important alternative financing method for startups and early-stage companies in Türkiye.

Instead of raising capital exclusively from:

• venture capital funds;
• angel investors;
• banks;
• strategic investors;

an eligible startup can potentially raise money from a broader investor community through an electronic crowdfunding platform.

In return for their investment, investors receive shares representing ownership in the funded company.

Türkiye has established a dedicated capital-markets framework for this business model.

The principal legislation is Capital Markets Law No. 6362 and the Crowdfunding Communiqué No. III-35/A.2, issued by the Capital Markets Board of Türkiye (“CMB” or “SPK”).

The current III-35/A.2 framework regulates both:

• equity-based crowdfunding; and
• debt-based crowdfunding.

The SPK’s official legislation system continues to list Communiqué III-35/A.2 as the governing crowdfunding regulation, originally published in the Official Gazette on 27 October 2021.

For companies wishing to establish an equity crowdfunding platform, however, incorporating an ordinary technology company and launching a website is not sufficient.

Crowdfunding platforms operate within a regulated capital-markets structure.

The company must satisfy requirements concerning:

• corporate form;
• minimum capital;
• founders and shareholders;
• board of directors;
• investment committee;
• information systems;
• internal control;
• risk management;
• conflicts of interest;
• Central Registry Agency (“MKK”) integration;
• custody of investor funds;
• investor onboarding;
• campaign disclosures.

The SPK’s current official list shows a developed Turkish equity crowdfunding market including platforms established by both dedicated crowdfunding companies and regulated financial institutions. As of July 2026, the SPK list contains 18 platforms authorised for equity-based crowdfunding, including the most recently listed Fonventure Kitle Fonlama Platformu A.Ş. in August 2025.

This article explains how to establish an equity crowdfunding platform in Turkey in 2026 and the principal legal requirements founders, investors and fintech groups should consider.

1. What Is Equity Crowdfunding?

Equity crowdfunding is a financing method through which investors provide money to a startup or eligible venture in exchange for shares.

A simplified structure is:

Startup → Crowdfunding Platform → Investors → Capital Increase → Investor Shares

Unlike donation crowdfunding, investors do not merely support a project.

Unlike reward crowdfunding, investors do not simply receive a product or benefit.

They become shareholders in the funded company.

The current Crowdfunding Communiqué specifically distinguishes equity-based crowdfunding from debt-based crowdfunding and regulates public fundraising conducted through authorised electronic platforms.

2. Equity Crowdfunding Is Different From an IPO

An equity crowdfunding campaign is not the same as an initial public offering on Borsa İstanbul.

The regulatory framework creates a special alternative fundraising route designed particularly for eligible ventures and early-stage businesses.

Crowdfunding is conducted through an SPK-regulated platform rather than through an ordinary stock exchange offering.

The crowdfunding framework also operates outside certain ordinary public offering procedures where the conditions under Capital Markets Law and the Communiqué are satisfied.

However, this should not create the impression that crowdfunding is unregulated.

In reality, crowdfunding has its own detailed investor-protection, disclosure, custody and platform-authorisation framework.

3. Can Any Company Establish a Crowdfunding Website in Turkey?

No.

A company cannot legally conduct regulated equity crowdfunding merely by:

• registering a domain;
• developing investment software;
• signing startups;
• collecting money from investors.

The Crowdfunding Communiqué requires regulated crowdfunding platforms to obtain the necessary SPK status before conducting crowdfunding activities.

The current consolidated Communiqué regulates both establishment approval and inclusion on the SPK list. Platforms cannot commence regulated crowdfunding simply because an anonymous company has been incorporated.

Therefore, founders should view the regulatory process as having two principal phases:

Establishment Approval

and

SPK List Inclusion / Operational Authorisation.

4. Step One: Establish a Turkish Joint-Stock Company

A crowdfunding platform must be structured as a Turkish joint-stock company (Anonim Şirket – A.Ş.).

The current Communiqué requires the platform to be an anonymous company and requires all shares to be registered shares.

This means structures such as:

• limited company;
• ordinary partnership;
• sole proprietorship

cannot directly become the regulated crowdfunding platform.

The platform’s articles of association must also comply with the crowdfunding regulatory framework.

5. The Company Name Must Include “Kitle Fonlama Platformu”

The regulated company’s trade name must contain:

“Kitle Fonlama Platformu”

meaning “Crowdfunding Platform.”

This requirement makes the regulated status of the entity identifiable from its legal corporate name.

For example:

XYZ Kitle Fonlama Platformu A.Ş.

can constitute an appropriate naming structure, subject to trade registry availability and regulatory approval.

The current regulatory framework expressly requires this expression in the platform’s commercial title.

6. Minimum Capital Requirement in 2026: TRY 15 Million

One of the most important financial requirements is minimum capital.

Although the base amount in the original Communiqué was lower, the thresholds under the Crowdfunding Communiqué are subject to annual revaluation.

For 2026, the SPK’s official revaluation decision sets the minimum capital requirement for establishment and listing of a crowdfunding platform at:

TRY 15,000,000.

The capital must satisfy the applicable paid-in capital and equity requirements under the Communiqué.

The SPK has also previously clarified that crowdfunding platforms must comply with annually revalued minimum capital and equity conditions by no later than the end of the sixth month of the relevant year.

Accordingly, founders should not use the historical TRY 1 million figure appearing in the original regulatory text when preparing a 2026 business plan.

The relevant current headline amount is TRY 15 million.

7. Capital Is Only the Beginning

TRY 15 million should not be interpreted as the total amount required to launch a crowdfunding platform.

The company must also finance:

• technology;
• cybersecurity;
• personnel;
• regulatory compliance;
• accounting;
• internal control;
• investment committee operations;
• MKK integration;
• legal documentation;
• marketing;
• startup due diligence.

A serious platform should therefore plan for operating capital beyond the statutory minimum.

8. Crowdfunding Must Be the Platform’s Principal Regulated Activity

The articles of association must reflect the platform’s regulated business.

The Communiqué requires the company’s business purpose to be specifically structured around providing equity and/or debt crowdfunding intermediation.

The regulatory model therefore does not envisage an ordinary e-commerce or software company casually adding crowdfunding as another unrelated business line.

This exclusivity requirement protects investors by creating a clearly identifiable regulated platform rather than mixing investor fundraising with unrelated commercial activities.

9. Board of Directors Requirements

The platform’s board must consist of at least:

three members.

Founders should not view these board positions as ceremonial.

The board is central to:

• compliance;
• risk management;
• internal controls;
• platform governance;
• investment committee appointments;
• conflicts policies.

Board members are also subject to regulatory suitability requirements.

10. Founder, Shareholder and Director Suitability

The Crowdfunding Communiqué imposes “fit and proper” standards on founders, significant shareholders and directors.

The regulatory framework examines matters such as:

• bankruptcy or insolvency history;
• certain regulatory sanctions;
• criminal convictions;
• integrity;
• reputation;
• capital-markets transaction restrictions.

This means an application is not assessed only from a capital perspective.

The SPK also examines the people behind the platform.

Corporate structures should therefore be reviewed before the application to identify:

• ultimate beneficial owners;
• significant shareholders;
• board nominees;
• indirect ownership chains.

Complex or opaque shareholder structures can materially complicate regulatory review.

11. Significant Share Transfers May Require SPK Approval

Regulatory scrutiny continues after the platform has been authorised.

Changes in platform ownership can require SPK approval depending on the relevant percentage thresholds or governance rights.

The current framework specifically regulates acquisitions or transfers affecting important ownership levels and shares conferring board representation rights.

Therefore, future:

• venture capital investments;
• strategic acquisitions;
• founder exits;
• group reorganisations

should be analysed for regulatory approval before the transaction closes.

A crowdfunding platform cannot be treated like an ordinary unregulated startup in M&A transactions.

12. An Investment Committee Is Mandatory

One of the defining governance requirements is the Investment Committee (Yatırım Komitesi).

The committee evaluates campaign applications and plays a key role in determining whether a startup should be permitted to raise money through the platform.

The current framework requires the committee to have at least:

three members.

The majority of its members must have at least five years of experience in relevant fields such as:

• finance;
• entrepreneurship;
• business;
• legal consultancy;
• technology;
• industry;
• commerce.

At least one member must also hold the required Level 3 Capital Markets Activities Licence under the applicable framework.

This requirement shows that the platform is expected to conduct substantive project screening rather than merely operating as an online notice board.

13. What Does the Investment Committee Do?

For equity crowdfunding, one of the investment committee’s most important duties is reviewing the campaign’s:

feasibility report

and

information form.

The committee develops objective assessment criteria and evaluates whether the proposed campaign meets the required standards.

The information form cannot simply be uploaded by a startup without platform review.

Under the regulatory framework, the investment committee must approve the information form before the equity crowdfunding campaign can be published.

The platform therefore performs a gatekeeping function.

14. Investment Committee Independence and Conflicts

The investment committee must operate under conflict-of-interest restrictions.

Members should not participate in evaluating campaigns where they or specified related persons have prohibited connections.

Committee members are also restricted from obtaining inappropriate economic benefits from companies or entrepreneurs whose campaigns they assess.

The platform should therefore maintain written conflict procedures covering:

• ownership interests;
• advisory relationships;
• family relationships;
• investment interests.

This becomes particularly important where platform founders are also active:

• angel investors;
• startup advisors;
• venture capital professionals.

15. Internal Control and Risk Management

Before list inclusion, the platform must establish appropriate:

• internal control;
• risk management;
• accounting;
• operational functions.

The platform must also employ sufficient personnel to maintain documentation, accounting and regulatory records.

These requirements reflect the fact that a crowdfunding platform processes:

• investment decisions;
• startup financial information;
• investor data;
• securities ownership information;
• large volumes of investment money.

It therefore cannot operate with the governance structure of an ordinary social media platform.

16. Information Systems Infrastructure

Technology is a regulatory requirement, not merely a commercial requirement.

The Crowdfunding Communiqué requires the platform to establish an information systems infrastructure compatible with the applicable SPK information systems framework.

The platform must be capable of supporting:

• investor membership;
• identity processes;
• campaign pages;
• investor orders;
• MKK reporting;
• custody communications;
• regulatory disclosures;
• records.

Cybersecurity should therefore be designed before the SPK application rather than after licence approval.

17. MKK Integration Is Fundamental

The Central Registry Agency (Merkezi Kayıt Kuruluşu – MKK) plays a central role in the Turkish crowdfunding ecosystem.

The platform must establish the required contracts and technological integrations with MKK.

MKK supports functions including:

• investor records;
• investment-limit controls;
• recording of equity positions;
• book-entry creation of shares.

The crowdfunding framework requires platform infrastructure to be aligned with MKK’s procedures.

This is particularly important because equity crowdfunding ultimately produces real corporate ownership rights.

The investor is not merely receiving a digital token displayed inside the platform.

Shares must be created and recorded through the regulated infrastructure.

18. The Platform Does Not Simply Hold Investor Money

Another central institution is the custodian/escrow authority (emanet yetkilisi).

The regulatory definition includes Takasbank and other qualifying portfolio custodians under the applicable capital-markets framework.

Investor funds are not intended to become ordinary operating money belonging to the crowdfunding platform.

During the campaign process, funds are blocked through the regulated custody structure until:

• the campaign successfully completes; or
• the funds must be returned.

This separation is a fundamental investor-protection mechanism.

19. Why the Escrow Structure Matters

Suppose a campaign seeks TRY 20 million.

Investors contribute TRY 15 million during the campaign, but the target is not achieved.

The platform should not have already spent the TRY 15 million.

The regulated structure allows funds to remain blocked until the legal conditions for the campaign are satisfied.

Where the fundraising conditions fail, funds are returned under the prescribed process.

This dramatically reduces the risks associated with a platform collecting investment money into its ordinary company bank account.

20. Platform Membership Is Required

Investors generally need to become members of the crowdfunding platform before investing.

The membership framework includes:

• identity verification;
• membership agreement;
• risk disclosures;
• investor suitability/risk understanding;
• qualified-investor verification where relevant.

The regulatory framework requires investors to acknowledge the General Risk Notification Form for Crowdfunding Activities and requires the platform to evaluate whether investors understand risks such as:

• complete loss of the investment;
• limited transferability of shares.

This is important because startup investing is inherently high risk.

21. 2026 Investor Limits

Investor limits are one of the most important current numerical requirements.

For 2026, a natural person who is not a qualified investor can invest a maximum of:

TRY 500,000

in equity and/or debt crowdfunding during one calendar year.

Where the person declares annual net income, the investment limit can instead be applied based on the relevant income formula, subject to a maximum of:

TRY 2,000,000.

These limits are updated through annual revaluation.

Platforms should therefore not hard-code historic investment limits permanently into their software.

The thresholds need regulatory maintenance.

22. MKK Controls Investor Limits

The Turkish crowdfunding structure does not leave annual investment-limit control entirely to each individual platform.

Investor information is communicated through the MKK framework, allowing the applicable investor limits to be monitored across the regulated system.

This is important because otherwise an investor could attempt to circumvent limits simply by investing the maximum amount through several different platforms.

The regulatory architecture instead creates a centralised control structure.

23. Qualified Investors Are Treated Differently

Qualified investors are subject to a different regulatory framework from ordinary retail individuals.

Platforms must verify qualified-investor status through MKK before creating the relevant membership status.

This is significant because qualified investors can play an important role in larger crowdfunding rounds.

For 2026, another important revalued threshold is:

TRY 9 million.

Where an equity crowdfunding fund request exceeds the current threshold corresponding to Article 16(5), the relevant minimum qualified-investor participation requirement applies. The 2026 revaluation decision increased the historical threshold to TRY 9 million.

Under the underlying rule, at least 10% of the targeted amount must be covered by qualified investors for campaigns exceeding the applicable threshold.

This creates an institutional or sophisticated-investor validation mechanism for larger campaigns.

24. Only Eligible Ventures Can Raise Equity Crowdfunding

Not every company can automatically launch an equity crowdfunding campaign.

The regulatory framework focuses particularly on eligible venture companies and projects.

Among the criteria historically and currently central to the regime are that qualifying venture companies operate in:

• technology activities;
• and/or production activities,

and satisfy the applicable startup-stage and financial criteria under the Communiqué.

The framework is therefore not designed as a general financing mechanism for every established business wishing to sell shares online.

A platform should conduct eligibility due diligence before accepting a campaign.

25. Equity Crowdfunding Requires an Anonymous Company Structure

One of the most important corporate-law rules is that equity crowdfunding ultimately results in investors receiving shares in a Turkish joint-stock company.

The current consolidated rules recognise entrepreneurs and limited companies within the application process, but the funded corporate structure must be brought into the required joint-stock company form before funds are finally transferred under the equity crowdfunding mechanics.

This matters particularly for Turkish startups initially incorporated as:

Limited Şirket (Ltd. Şti.).

Such a company may need to convert into an A.Ş. as part of the funding process.

26. Existing Founder Shares Cannot Simply Be Sold to the Crowd

Equity crowdfunding is designed to provide new funding to the venture.

The current framework requires the fundraising to occur through shares issued in connection with a capital increase.

Existing shares of the venture company cannot simply be sold through the equity crowdfunding campaign as a secondary founder exit.

This distinction is fundamental.

Permitted Core Model

Investor money → company capital increase → company receives growth capital.

Not the Ordinary Equity Crowdfunding Model

Investor money → founder sells personal existing shares → founder takes cash.

The regulatory objective is financing the venture rather than providing founders with an online exit market.

27. Share Rights Must Be Disclosed

The information form must clearly explain the rights attached to investor shares.

This can include:

• voting rights;
• economic rights;
• privileges;
• nominal value;
• sale price.

The framework restricts creating different privileges between ordinary retail investors, subject to the separate treatment of qualified investors.

A crowdfunding campaign should therefore not advertise simply:

“Own 1% of the company”

without clearly explaining the rights attached to that ownership.

28. Information Form Is the Core Disclosure Document

The Information Form (Bilgi Formu) is the central disclosure document for the campaign.

The SPK determines standard forms for crowdfunding disclosures.

In December 2025, the SPK formally updated the Equity-Based Crowdfunding Information Form for Entrepreneurs and the Equity-Based Crowdfunding Information Form for Venture Companies, alongside new debt crowdfunding forms.

Accordingly, a platform launching campaigns in 2026 should use the current SPK information-form standards rather than old templates.

29. What Should the Information Form Accomplish?

The information form should allow an investor to understand the material characteristics and risks of the proposed investment.

Depending on the structure, disclosures can include matters concerning:

• venture;
• founders;
• project;
• financial position;
• funding target;
• share price;
• use of proceeds;
• investor rights;
• material risks.

The investment committee must review the form before publication.

Crowdfunding disclosure therefore occupies a middle ground between an informal startup pitch deck and a full public-offering prospectus.

30. Campaign Duration Cannot Exceed 60 Days

Once the investment committee approves the information form and it is published on the campaign page, the active fundraising period begins.

The regulatory campaign period cannot exceed:

60 days.

The company and platform should therefore prepare marketing and investor communication before the formal campaign begins.

A campaign cannot remain indefinitely open while waiting for investors.

31. Investors Have a 48-Hour Withdrawal Right

Another important investor-protection feature is the withdrawal right.

An investor may withdraw from a funding request without giving a reason by notifying the platform within:

48 hours

after issuing the relevant payment order.

The escrow authority then performs the necessary refund process under the regulatory timetable.

The platform’s software should therefore include an operationally reliable withdrawal mechanism.

32. Campaign Funds Are Blocked During the Process

Investor funding requests are communicated to MKK and the escrow/custodian infrastructure.

Collected funds remain blocked rather than being immediately available to the startup.

If the target and other conditions are satisfied, the campaign progresses toward:

• company formation/conversion where necessary;
• capital increase;
• MKK creation of shares;
• allocation of shares to investors.

If the conditions are not satisfied, investor funds are returned.

This structure is one of the strongest legal protections in Turkish crowdfunding.

33. Capital Increase After a Successful Campaign

Where an existing joint-stock venture company successfully completes the campaign, it must complete the required capital increase within the regulatory period.

The crowdfunding rules require the collected funding to be reflected through an appropriate capital increase and subsequent creation of investor shares.

The process then involves MKK recording the company’s shares and allocating investor holdings.

The platform therefore needs close cooperation between:

• corporate lawyers;
• accountants;
• MKK;
• the custodian;
• the funded company.

34. Founders Cannot Immediately Sell Out After Crowdfunding

Crowdfunding investors naturally face founder-departure risk.

The regulatory framework therefore imposes restrictions on founders and certain existing shareholders transferring their shares during the period following commencement of the campaign, subject to defined exceptions.

The historic Article 16 framework establishes a three-year transfer restriction with exceptions for specified transfers such as certain transfers between founders or to qualified investors.

This supports alignment between founders and new crowdfunding investors.

35. Up to Two Equity Crowdfunding Campaigns in Twelve Months

The current regulatory framework limits how frequently the same entrepreneur or venture can raise equity crowdfunding.

A venture company or entrepreneur may conduct a maximum of:

two equity crowdfunding campaigns

through platforms during any twelve-month period.

The total amount raised remains subject to the annually applicable SPK issuance ceiling.

A startup therefore cannot continuously run back-to-back crowdfunding rounds without limitation.

36. Additional Funding Can Be Collected

The framework permits a campaign, where properly disclosed and within the applicable overall issuance ceiling, to collect additional funds above the primary target.

The current Article 16 structure allows an additional amount of up to:

20% of the requested crowdfunding amount

subject to the regulatory requirements and information-form disclosure.

Platforms should code this functionality carefully because overfunding rules must treat investors consistently.

37. Campaign Failure Means Investor Refund

If the campaign does not meet the required funding target within the permitted timeframe, the blocked investor amounts and applicable returns are refunded through the escrow mechanism.

The platform cannot simply:

• reduce the target retrospectively;
• send partially collected funds to the company;
• retain investor money.

The regulatory framework prescribes how unsuccessful campaigns are closed and funds returned.

38. The Platform Must Remain Neutral

Crowdfunding platforms are not ordinary investment promoters.

They have duties to protect investors and apply campaign-selection criteria fairly.

The platform should maintain procedures ensuring consistent treatment of:

• startups;
• investors;
• information disclosure.

The regulatory framework also requires a written conflict-of-interest policy approved by the platform board.

This is particularly important where the platform has commercial relationships with venture capital funds or angel investors.

39. Related-Party Campaign Restrictions

The platform cannot simply use its regulated website to raise funds for itself or certain closely related businesses.

Current rules restrict campaigns involving:

• the platform itself;
• specified companies in which the platform has significant ownership or governance interests;
• companies linked at specified levels to platform shareholders, directors or investment committee members and their close relatives.

These restrictions exist to reduce conflicts between:

platform revenue generation

and

investor protection.

40. No General Secondary Market Through an Ordinary Platform

An important investor risk concerns liquidity.

Crowdfunding shares are not automatically traded on a liquid exchange.

The regulatory framework restricts ordinary crowdfunding platforms from intermediating secondary-market transactions in shares or debt instruments, with specific treatment for authorised investment institutions. Allowing members to communicate with one another does not itself amount to prohibited secondary-market intermediation.

Investors should therefore understand:

crowdfunding shares may be difficult to sell.

The platform must communicate this risk clearly.

41. Foreign Crowdfunding Platforms Targeting Turkey

Foreign platforms should be cautious before marketing equity crowdfunding to Turkish residents.

The Crowdfunding Communiqué contains a cross-border rule.

Where a foreign platform does not market or promote crowdfunding services to persons resident in Türkiye and Turkish residents independently use the foreign platform, the transaction can fall outside the Turkish crowdfunding regime in the circumstances specified by the Communiqué.

However, activities indicating Turkish targeting can bring the platform within the Turkish framework.

Examples include:

• opening a workplace in Türkiye;
• creating a Turkish-language website;
• directly marketing crowdfunding activities to Turkish residents;
• marketing through Turkish persons or organisations.

A foreign crowdfunding licence therefore does not automatically passport into Türkiye.

42. Foreign Investment Through Turkish Crowdfunding Platforms

The framework is not necessarily limited exclusively to Turkish individual investors.

For persons not resident in Türkiye, membership procedures require the appropriate MKK account and registration architecture under the regulatory rules.

International investor participation can therefore be possible, but:

• MKK procedures;
• Turkish foreign-investment rules;
• tax;
• KYC;
• payment flows

should be reviewed separately.

43. KVKK Compliance

Crowdfunding platforms process extensive personal data.

This may include:

• investor identity information;
• income declarations;
• investment activity;
• startup founder information;
• beneficial ownership data;
• risk assessment information.

The Crowdfunding Communiqué itself expressly requires compliance with Law No. 6698 on the Protection of Personal Data (KVKK) when platform information is shared with third parties.

Crowdfunding platforms should therefore maintain:

• privacy notices;
• data-processing inventories;
• access controls;
• security measures;
• data transfer procedures.

44. Investor Income Information Is Particularly Sensitive

Non-qualified investors can increase their annual investment capacity based on declared annual net income, subject to the applicable regulatory ceiling.

The platform therefore processes financially sensitive information concerning users.

For 2026, the income-based annual maximum can reach TRY 2 million.

Access to this information should be restricted to authorised operational and compliance functions.

It should not automatically become advertising data.

45. MASAK and Financial Crime Risk

Crowdfunding can also create financial crime risks.

Potential risks include:

• false investors;
• fraud campaigns;
• use of companies to move criminal proceeds;
• fictitious founders;
• suspicious third-party payments.

The platform should ensure investor funding comes through payment instruments compatible with the investor’s verified identity, as required by the campaign process.

Where banks, custodians and other obliged financial institutions participate, their own MASAK obligations also become relevant.

A platform should therefore build financial-crime controls into the investment flow rather than relying solely on startup due diligence.

46. Startup Due Diligence Is Essential

The platform should not accept a startup simply because its pitch is commercially attractive.

Before the investment committee approves a campaign, due diligence should consider matters such as:

• incorporation;
• shareholders;
• founders;
• intellectual property;
• financial statements;
• litigation;
• material agreements;
• regulatory licences;
• use of proceeds.

The investment committee’s approval does not guarantee that the startup will succeed.

However, the platform must operate a credible screening and disclosure process.

47. Intellectual Property Can Be Critical

Technology startups often derive most of their value from intellectual property.

A platform evaluating a software startup should therefore consider:

• Who owns the source code?
• Have founders assigned IP rights to the company?
• Are trademarks registered?
• Does the company depend on third-party licences?
• Are former employees claiming rights?

An investor purchasing equity in a company whose founders personally own the core software faces a fundamentally different risk from an investor in a company that properly owns its technology.

48. Use of Funds Must Be Monitored

Crowdfunding money should be used for the purpose disclosed to investors.

The regulatory framework includes rules regarding:

• reports on intended use;
• verification and monitoring;
• investor disclosure.

For equity crowdfunding, higher fund amounts can trigger additional independent audit/reporting requirements.

For 2026, the revalued threshold relevant to the special independent audit timing rule for equity crowdfunding is:

TRY 9 million.

The platform should therefore continue monitoring after the campaign closes.

Its regulatory responsibilities do not necessarily end when the money is transferred.

49. SPK Updated Equity Crowdfunding Information Forms in December 2025

One of the most important current developments occurred at the end of 2025.

On 23 December 2025, the SPK updated:

• the Equity-Based Crowdfunding Information Form for Entrepreneurs;
• the Equity-Based Crowdfunding Information Form for Venture Companies.

The forms are currently published through the SPK’s crowdfunding information-form page.

Platforms operating in 2026 should therefore review their campaign-document workflows against the current forms rather than relying on historical templates.

50. Current Turkish Equity Crowdfunding Market

Türkiye now has a material regulated equity crowdfunding ecosystem.

The SPK’s official platform list currently includes:

• investment firms;
• investment bank participation;
• dedicated crowdfunding companies.

The official list presently shows 18 entities authorised for equity crowdfunding, with listing dates extending from April 2021 through August 2025.

This indicates that equity crowdfunding has moved beyond a purely experimental regulatory phase.

A new applicant is entering an increasingly professional market.

51. Step-by-Step: How to Establish an Equity Crowdfunding Platform in Turkey

A practical establishment process can be summarised as follows.

Step 1: Determine the Platform Scope

Decide whether the platform will provide:

• equity crowdfunding only; or
• equity and debt crowdfunding.

Debt crowdfunding creates additional infrastructure and expertise requirements.

Step 2: Prepare the Founder and Ownership Structure

Identify:

• founders;
• ultimate beneficial owners;
• significant shareholders;
• board nominees.

Verify fit-and-proper requirements before filing.

Step 3: Prepare SPK-Compliant Articles of Association

The company must be an A.Ş., its shares must be registered and its commercial title must contain “Kitle Fonlama Platformu.”

The business scope should reflect the regulated crowdfunding activity.

Step 4: Provide TRY 15 Million Capital

The 2026 minimum platform capital requirement is TRY 15 million.

Step 5: Obtain Establishment Approval

The founders submit the required corporate documentation and suitability evidence to the SPK.

Step 6: Incorporate the Company

Following the regulatory establishment process, complete the relevant Turkish corporate and trade registry formalities.

Step 7: Build Governance

Establish:

• board;
• investment committee;
• internal controls;
• risk management;
• accounting and operations.

Step 8: Build Information Systems

Develop secure:

• platform infrastructure;
• member onboarding;
• campaign system;
• disclosures;
• transaction records.

Step 9: Complete MKK and Custodian Integration

Contract and technically integrate with:

• MKK;
• the appropriate escrow/custody institution.

Step 10: Prepare Conflicts and Operating Policies

Document procedures concerning:

• conflicts;
• campaign evaluation;
• complaints;
• data;
• cybersecurity;
• outsourcing.

Step 11: Apply for SPK List Inclusion

Operational crowdfunding cannot begin until the platform is accepted into the relevant SPK list.

Step 12: Launch Only After Authorisation

Do not begin collecting crowdfunding money during the application process.

The SPK’s current official list is the key public reference for entities permitted to conduct the regulated activity.

Equity Crowdfunding Platform Compliance Checklist

Before applying to establish an equity crowdfunding platform in Türkiye, founders should verify:

Corporate Form

Is the company structured as an A.Ş.?

Capital

Is at least TRY 15 million available under the 2026 requirement?

Shares

Are all platform shares registered?

Trade Name

Does it contain “Kitle Fonlama Platformu”?

Shareholders

Do founders and significant shareholders meet fit-and-proper requirements?

Board

Are there at least three directors?

Investment Committee

Has the required committee been formed with appropriate expertise and licensing?

Internal Controls

Are risk, accounting and operational functions operational?

Technology

Does the infrastructure satisfy applicable capital-markets information-system requirements?

MKK

Is the required integration operational?

Custody

Is the escrow/custodian structure operational?

Conflicts

Has a board-approved conflict-of-interest policy been prepared?

Investor Onboarding

Can investor identity, qualified status and annual limits be verified?

Risk Disclosure

Is the prescribed crowdfunding risk form built into membership?

Information Forms

Are the current SPK forms used?

KVKK

Is personal data processing documented?

Campaign Governance

Can the platform enforce the 60-day maximum campaign period and 48-hour investor withdrawal right?

Frequently Asked Questions About Equity Crowdfunding in Turkey

Is equity crowdfunding legal in Turkey?

Yes. Equity crowdfunding is expressly regulated under Capital Markets Law No. 6362 and the Crowdfunding Communiqué No. III-35/A.2.

Which authority regulates crowdfunding platforms?

The Capital Markets Board of Türkiye, or SPK, regulates and supervises crowdfunding platforms. Its Intermediary Activities Department examines platform establishment and list applications.

Is there a crowdfunding platform licence?

The Turkish model involves SPK establishment approval and inclusion on the regulated crowdfunding platform list. A platform cannot legally conduct the activity merely through ordinary company incorporation.

What is the minimum capital in 2026?

The minimum establishment/listing capital requirement is TRY 15 million for 2026.

Must the platform be an A.Ş.?

Yes. Crowdfunding platforms must be established as joint-stock companies.

How many board members are required?

The board must have at least three members.

Does the platform need an investment committee?

Yes. An investment committee is a core element of the regulatory structure and must satisfy membership, experience and licensing requirements.

What is the 2026 retail investor limit?

A non-qualified natural person may generally invest up to TRY 500,000 per calendar year through equity and debt crowdfunding.

Can the investor limit increase based on income?

Yes. Where annual net income is declared under the regulatory framework, the limit can rise subject to the applicable formula, with a 2026 maximum of TRY 2 million.

How long can an equity crowdfunding campaign remain open?

The campaign period cannot exceed 60 days.

Can an investor cancel an investment?

Yes. The regulatory framework provides a 48-hour withdrawal right after the investor issues the payment order.

Does the platform hold investor money itself?

Investor money is handled through the prescribed escrow/custodian structure rather than being treated as ordinary operating money belonging to the platform.

Can an existing shareholder sell shares through an equity crowdfunding campaign?

The ordinary equity crowdfunding structure raises capital through newly issued shares resulting from a capital increase; existing shares cannot simply be sold as the fundraising mechanism.

Can a limited company raise equity crowdfunding?

The current framework permits limited-company entrepreneurs/ventures within the process, but the funded structure must satisfy the required conversion into a joint-stock company before the relevant funds and shares are finally processed.

Are crowdfunding shares recorded with MKK?

Yes. The framework requires the funded company’s shares to be created in book-entry form and investor rights to be reflected through MKK.

How many campaigns can a startup conduct?

A venture company or entrepreneur may generally conduct no more than two equity crowdfunding campaigns in a twelve-month period, subject to the applicable total fundraising ceiling.

Can a campaign raise above its target?

Subject to disclosure and applicable limits, equity crowdfunding can permit up to 20% additional funding over the requested amount.

Can a foreign crowdfunding company target Turkey?

A foreign platform targeting Turkish residents through a Turkish website, local presence or marketing can fall within the Turkish crowdfunding framework. The Communiqué contains a narrower exemption for unsolicited offshore participation by Turkish residents in specified circumstances.

How many authorised equity crowdfunding platforms are currently listed?

As of July 2026, the SPK’s current public list shows 18 platforms authorised for equity-based crowdfunding.

Conclusion: How to Establish an Equity Crowdfunding Platform in Turkey

Establishing an equity crowdfunding platform in Turkey is significantly different from launching an ordinary fintech marketplace.

The business operates within the Turkish capital-markets regulatory system.

The principal legal framework is Capital Markets Law No. 6362 and the Crowdfunding Communiqué No. III-35/A.2, which remains the current core SPK regulation for equity and debt crowdfunding.

The first major requirement is corporate structure.

The platform must be organised as a Turkish joint-stock company.

Its shares must be registered, its commercial name must include “Kitle Fonlama Platformu,” and its corporate purpose must comply with the crowdfunding framework.

The second major requirement is financial capacity.

For 2026, the applicable minimum capital for establishment and listing is:

TRY 15 million.

Founders should remember that this is merely the statutory capital floor.

Operating a credible platform also requires significant investment in:

• cybersecurity;
• MKK integration;
• personnel;
• governance;
• startup due diligence;
• legal compliance.

The third requirement is governance.

A minimum three-member board is required, founders and directors must satisfy regulatory suitability requirements and the platform must establish a qualified investment committee.

The investment committee is particularly important because it is not merely advisory.

It reviews the feasibility and disclosure materials submitted by companies seeking investor funding.

A campaign cannot proceed simply because a founder pays the platform a listing fee.

The information form must pass the regulatory evaluation process.

The fourth pillar is investor protection.

Investors become members of the platform through an electronic process that incorporates:

• identity verification;
• membership contracts;
• risk disclosures;
• assessment of crowdfunding investment risks.

The regulatory framework expressly recognises that investors can lose the entirety of their investment and that crowdfunding shares may have limited transferability.

For non-qualified individual investors, the current annual investment ceiling has increased substantially.

In 2026, the ordinary limit is TRY 500,000.

Where the investor declares annual net income, the regulatory ceiling can reach TRY 2 million under the applicable formula.

The fifth pillar is the custody and MKK structure.

The crowdfunding platform is not designed to collect investor cash into its ordinary operational account.

Investor money is handled through the prescribed escrow/custodian framework and remains blocked during the campaign process.

MKK provides another crucial control layer.

It contributes to:

• investor identification;
• investment-limit controls;
• book-entry ownership records;
• creation of funded-company shares.

This means Turkish equity crowdfunding produces legally recognisable corporate ownership rather than merely displaying an informal “investment balance” inside an application.

The sixth pillar is campaign disclosure.

The information form is one of the most important legal documents in the entire crowdfunding process.

In December 2025, the SPK updated the official information forms for equity crowdfunding by both entrepreneurs and venture companies.

Platforms operating in 2026 should therefore use current SPK documentation and update legal templates whenever the regulator changes disclosure standards.

The seventh pillar concerns the actual mechanics of equity fundraising.

The purpose of equity crowdfunding is generally to inject new capital into the funded company.

The regulatory framework therefore requires fundraising through newly issued shares associated with a capital increase.

It does not operate as a general online secondary-market mechanism allowing founders to sell their old shares to retail investors.

This distinction is central to investor protection.

Investor money should enter the company and finance growth.

It should not simply become liquidity for an exiting founder.

The campaign itself is also tightly structured.

Once the investment committee-approved information form is published, the active fundraising period begins and cannot exceed 60 days.

Investors retain a 48-hour right to withdraw after issuing the payment order.

If the campaign succeeds, the corporate capital increase, MKK registration and transfer of funds follow.

If the campaign fails, blocked funds are returned.

Larger campaigns receive additional scrutiny.

For 2026, the threshold relevant to the qualified-investor participation mechanism has been revalued to TRY 9 million.

For equity campaigns above the relevant threshold, the underlying regulatory framework requires at least 10% of the targeted amount to be provided by qualified investors.

This requirement is commercially important.

A company planning a TRY 30 million crowdfunding round cannot necessarily rely entirely on thousands of small retail investors.

It must structure the round with the sophisticated-investor requirement in mind.

Another important distinction concerns startup eligibility.

The crowdfunding framework has primarily been designed for ventures carrying out technology and/or production activities and satisfying the regulatory startup criteria.

Consequently, platforms should perform regulatory eligibility analysis before committing significant resources to due diligence.

A traditional mature trading company should not automatically be treated as an eligible crowdfunding venture simply because it wants capital.

For foreign fintech businesses, Turkish crowdfunding regulation creates another strategic consideration.

A foreign platform that merely exists online and is independently discovered by a Turkish investor may fall under the offshore treatment provided by the Communiqué in the specified circumstances.

However, once the foreign platform actively targets Türkiye—through a Turkish-language website, local office or direct Turkish marketing—the Turkish regulatory framework can become applicable.

A European or UK crowdfunding authorisation therefore does not create a general regulatory passport into Türkiye.

Finally, the current market demonstrates that the licensing regime is functioning in practice.

The SPK’s current list contains 18 equity crowdfunding platforms, including dedicated crowdfunding companies, investment firms and an investment bank.

A new entrant should therefore expect regulatory and commercial competition.

The most effective approach is to design the platform as a financial-market institution from the beginning rather than building an ordinary startup investment website and attempting to retrofit compliance later.

The recommended establishment sequence is:

determine equity/debt scope → structure founders and shareholders → prepare SPK-compliant articles → secure TRY 15 million capital → obtain establishment approval → incorporate → appoint board and investment committee → establish internal controls and risk management → build information systems → integrate MKK and custodian → prepare investor/campaign policies → apply for SPK list inclusion → launch only after regulatory approval.

For founders, fintech investors and financial groups, the central legal principle can therefore be summarised as follows:

In Türkiye, equity crowdfunding is not simply online startup investing. It is a regulated capital-markets activity conducted through SPK-authorised infrastructure.

The technology may make investing simple.

Behind that interface must exist:

• licensed corporate structure;
• qualified governance;
• investor protection;
• regulated custody;
• MKK registration;
• reliable disclosures.

When these elements are correctly structured, equity crowdfunding can provide Turkish startups with a powerful alternative to conventional venture capital while giving individual investors regulated access to early-stage investment opportunities.

Legal Disclaimer: This publication provides general information concerning equity crowdfunding, crowdfunding platforms and capital-markets regulation in Türkiye as of July 2026. It does not constitute legal, investment, financial, tax or regulatory advice. Capital thresholds, investor limits, issuance ceilings and SPK requirements may be periodically revalued or amended. Each proposed crowdfunding platform, campaign and investment structure should therefore be individually assessed under Capital Markets Law No. 6362, Crowdfunding Communiqué No. III-35/A.2, current SPK decisions, MKK procedures, KVKK and other applicable Turkish legislation before establishment or launch.