Introduction

Türkiye has become an increasingly significant market for digital payments, mobile wallets, prepaid products, embedded finance and other financial technology services. As more businesses seek to hold customer balances and enable digital payments, the distinction between a conventional technology company and a regulated electronic money institution has become particularly important.

An entrepreneur cannot lawfully establish an ordinary software company, collect money from users, convert that money into a digital balance and allow customers to use that balance across a payment ecosystem without first considering Turkish financial regulation.

Where the business model legally constitutes the issuance of electronic money, authorization from the Central Bank of the Republic of Türkiye (“CBRT” or “TCMB”) is generally required.

The principal legislation governing electronic money institutions in Türkiye is Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions and the Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers. The CBRT has been responsible for regulating and supervising payment services and electronic money issuance since 1 January 2020.

Obtaining an electronic money institution license in Turkey is not simply an administrative registration exercise. It requires careful planning concerning company structure, shareholders, capital, minimum own funds, management, information systems, safeguarding of customer funds, anti-money laundering controls, customer agreements, data protection and operational readiness.

The regulatory environment has also become substantially more demanding. From 30 June 2026, the minimum own-funds requirement applicable to electronic money institutions increased to TRY 105 million.

This guide explains the Turkish electronic money licensing regime from both a legal and practical perspective.

1. What Is Electronic Money Under Turkish Law?

Understanding the legal definition of electronic money is the starting point for determining whether a licence is required.

Law No. 6493 defines electronic money as monetary value that is:

• issued against funds received by the electronic money issuer;
• stored electronically;
• used to carry out payment transactions; and
• accepted as a payment instrument by natural or legal persons other than the issuer itself.

This definition contains several elements that must normally exist together.

A digital balance is therefore not automatically electronic money.

For example, a company may provide loyalty points that can only be used to obtain its own goods or services. Depending on the precise structure, that arrangement may differ materially from an open wallet where customers deposit Turkish lira, receive corresponding digital value and spend that value with unrelated merchants.

The legal analysis should consider the economic reality rather than merely the terminology used by the company.

Calling a customer balance:

“credits,”
“tokens,”
“points,”
“wallet balance,” or
“digital funds”

does not automatically take the product outside electronic money regulation.

If the product performs the legal function of electronic money, the terminology used in marketing materials will not solve the regulatory problem.

2. Who Is Permitted to Issue Electronic Money in Turkey?

Electronic money issuance is a regulated activity.

Under Article 18 of Law No. 6493, electronic money may be issued by authorised institutions falling within the legal framework. An electronic money institution wishing to issue electronic money under Law No. 6493 must obtain permission from the CBRT.

The CBRT maintains an official list of authorised electronic money institutions and identifies the additional payment services each institution is authorised to provide.

Importantly, all companies appearing as authorised electronic money institutions are entitled to issue electronic money under Article 18, but the additional payment services available to them depend on the precise scope of their respective licences.

This distinction is fundamental.

An electronic money licence does not necessarily mean that the institution may perform every payment service recognised by Turkish law.

If an institution intends to provide additional services, such as particular money-transfer, acquiring, payment initiation or account information services, those activities must fall within the scope of its regulatory authorisation.

3. Electronic Money Institution vs Payment Institution in Turkey

The terms payment institution and electronic money institution are sometimes incorrectly used interchangeably.

They are related but legally distinct.

A payment institution is primarily authorised to provide one or more payment services falling under Article 12 of Law No. 6493.

An electronic money institution, by contrast, is authorised to issue electronic money.

An electronic money institution may also provide payment services where those services are included within its CBRT authorisation. The CBRT’s public register demonstrates this structure by separately identifying electronic money issuance and Article 12 payment-service permissions.

The distinction becomes particularly important for digital wallet projects.

Consider two simplified models.

Model A – Payment Processing

A fintech platform processes a customer’s payment from a bank account to a merchant but does not create a reusable customer balance.

Depending on the exact structure, this may involve payment services without electronic money issuance.

Model B – Stored Wallet Balance

A customer transfers TRY 5,000 into an application. The customer receives TRY 5,000 worth of digital monetary value stored in the wallet and can subsequently use that balance with participating merchants.

This type of structure is much more likely to raise electronic money questions.

Every fintech project should therefore map the customer journey and fund flow before determining which licence is necessary.

4. Is a Digital Wallet an Electronic Money Product?

Not necessarily.

A digital wallet is a broad technological concept rather than a single legal category.

Turkish payment regulations contain a specific definition of digital wallet services and regulate certain wallet structures within the payments framework. The regulatory definition introduced into the Payment Services Regulation refers broadly to services or applications that store information concerning payment accounts or payment instruments and enable customers to carry out transactions using those details.

A digital wallet may therefore operate in different ways.

It may:

• merely store card information;
• facilitate payment with an existing bank account;
• store electronic money;
• combine several payment instruments;
• permit peer-to-peer transfers;
• enable merchant payments;
• provide open banking functionality.

The required regulatory permission depends on these functions.

An entrepreneur should therefore avoid assuming:

“It is only a wallet, so an electronic money licence is unnecessary.”

The legal question is not the commercial name of the application.

The question is what happens to customer money after it enters the ecosystem.

5. Corporate Form Required for an Electronic Money Institution

An electronic money institution authorised under Law No. 6493 must be established as a Turkish joint-stock company, known as an anonim şirket or A.Ş.

Article 18 of Law No. 6493 requires the institution to:

• be established as a joint-stock company;
• satisfy specified shareholder requirements;
• issue its shares against cash;
• have registered shares;
• maintain the required paid-in capital;
• maintain a transparent and clear ownership structure suitable for regulatory supervision.

This has important consequences for foreign investors.

A foreign fintech entrepreneur should not automatically establish a Turkish limited liability company and postpone the licensing analysis.

Where the intended business clearly involves electronic money issuance, the corporate vehicle should normally be designed around the regulatory regime from the beginning.

The articles of association should also accurately reflect the company’s intended regulated operations.

6. Minimum Paid-In Capital Requirement

The statutory minimum paid-in capital required for an electronic money institution is TRY 5 million.

Article 18 of Law No. 6493 provides that the institution must have at least TRY 5 million of paid-in cash capital free from any collusive arrangement. The current Payment Services Regulation likewise requires at least TRY 5 million in paid-in capital for a company applying to issue electronic money.

However, this figure must be understood carefully.

TRY 5 million is not the amount that is practically sufficient to operate an electronic money institution in 2026.

It is the statutory paid-in capital requirement relevant to the corporate and licensing structure.

A much higher separate requirement applies to regulatory own funds.

Confusing these two concepts is one of the most common mistakes when researching the cost of an electronic money licence in Türkiye.

7. Minimum Own Funds for Electronic Money Institutions in 2026

As of 30 June 2026, the minimum own-funds requirement for an electronic money institution is:

TRY 105,000,000

The CBRT increased the previous TRY 80 million threshold to TRY 105 million through the communiqué published in the Official Gazette on 31 January 2026. The new amount entered into force on 30 June 2026.

Accordingly, investors should clearly distinguish between:

Statutory paid-in capital: TRY 5 million

and

2026 minimum own-funds threshold: TRY 105 million.

The practical financial planning for an electronic money institution should therefore be based on the considerably higher regulatory own-funds requirement.

Moreover, minimum regulatory own funds should not necessarily be treated as the total amount of capital required to establish a commercially sustainable fintech company.

The business must also finance:

• technology infrastructure;
• personnel;
• cybersecurity;
• regulatory advisers;
• independent audits;
• compliance systems;
• office infrastructure;
• marketing;
• customer support;
• banking relationships;
• insurance and guarantees where applicable.

A realistic investment budget will therefore usually exceed the legal minimum.

8. Shareholder Requirements

Regulation of electronic money institutions extends to shareholders and persons exercising control.

Under Law No. 6493, persons holding 10% or more of the company’s capital, as well as persons exercising control, must satisfy the qualifications required for bank founders under Banking Law No. 5411.

The CBRT licensing procedure accordingly involves substantial scrutiny of shareholders.

The regulator may examine matters including:

• identity of shareholders;
• ultimate beneficial ownership;
• source of investment funds;
• financial standing;
• criminal history;
• bankruptcy and insolvency history;
• corporate relationships;
• control arrangements;
• direct and indirect shareholdings.

The current licensing regulation requires extensive documentation concerning qualifying shareholders and persons exercising control during the intelligence-review stage.

For international groups, ownership should therefore be structured transparently.

A highly complicated holding structure may create additional regulatory questions, particularly where ultimate beneficial ownership is difficult to determine.

9. Foreign Shareholders and Foreign Financial Institutions

Foreign investors may invest in Turkish fintech companies, including regulated electronic money institutions, subject to the applicable Turkish regulatory requirements.

Where a corporate shareholder or controlling entity is a foreign bank or financial institution, additional documentation may be required.

The current CBRT licensing regulation provides for documents including, where applicable:

• corporate resolutions relating to operations in Türkiye;
• the latest consolidated independent audit report;
• documentation from the relevant foreign supervisory authority confirming that the institution is not prohibited or restricted from operating;
• detailed information concerning its activities, organisation and international financial operations.

Therefore, foreign investment itself is not prohibited.

However, foreign ownership does not eliminate the Turkish licensing requirement.

A company licensed as an electronic money institution in another jurisdiction should not assume that its foreign EMI licence automatically allows it to issue electronic money to customers in Türkiye.

10. CBRT Electronic Money Licence Application Process

Applications for an electronic money licence are submitted to the Central Bank of the Republic of Türkiye.

The current application regime has several stages.

Broadly, the process includes:

1. preliminary application before registration of the regulated trade name;
2. establishment of the company;
3. intelligence review;
4. final approval;
5. operational readiness review;
6. publication of the licence;
7. commencement-of-activity notification.

The Regulation expressly states that authorisation applications under Articles 14 and 18 of Law No. 6493 consist of an intelligence review stage and a final approval stage.

This means an EMI licensing project should not be viewed as the submission of a single administrative form.

The CBRT effectively examines whether the proposed institution is legally, financially, operationally and technologically capable of carrying out regulated financial activity.

11. Preliminary Application and Application Fee

The company’s trade name must include wording showing that it is an electronic money institution.

Before registering a trade name containing the relevant regulated wording with the trade registry, the applicant must submit the required forms, draft articles of association and supporting documentation to the CBRT.

The current Regulation provides for an initial application fee of TRY 500,000, together with the applicable statutory charges. The fee is not refunded if the application is later unsuccessful.

Following the preliminary submission, the CBRT issues documentation confirming commencement of the application procedure.

The applicant generally has six months following notification to proceed to the intelligence-review stage.

This time limit makes proper preparation essential.

An applicant should not begin the formal process before it has a realistic strategy for completing the corporate, financial and regulatory documentation.

12. Intelligence Review Stage

The intelligence-review stage is one of the most important components of the electronic money institution licensing process in Turkey.

At this stage, the CBRT examines matters including:

• the proposed activities;
• business plan;
• corporate structure;
• shareholders;
• persons exercising control;
• financial capacity;
• management;
• ownership of funds used for capital;
• financial statements;
• organisational structure;
• risk profile.

The Regulation requires a board resolution approving the application and a detailed activity programme and business plan signed by the relevant members of management. It also requires extensive documentation relating to qualifying shareholders, ultimate control, financial standing and other eligibility matters.

The business plan should clearly explain:

• the proposed electronic money product;
• target customers;
• wallet structure;
• issuance mechanism;
• redemption mechanism;
• merchant network;
• expected transaction volume;
• expected electronic money outstanding;
• revenue model;
• banking arrangements;
• payment services to be offered;
• technology infrastructure;
• distribution channels;
• risk-management framework.

The business model described in the application should correspond with what the company actually plans to implement.

13. Final Approval Stage

Approval of the intelligence-review stage does not mean the applicant is licensed.

Following approval of the intelligence stage, the company must generally submit its final-approval application within 120 days after written notification.

The CBRT may extend this period for up to an additional 60 days where the applicant submits reasonable justification.

At this point, the regulator expects substantially greater operational readiness.

The final review includes examination of whether the applicant has established:

• sufficient capital and own funds;
• internal controls;
• risk management;
• accounting infrastructure;
• information systems;
• regulatory reporting systems;
• customer complaint units;
• appropriate staff;
• business continuity measures;
• information-security measures.

The Regulation also provides for independent assessment of the relevant systems and an on-site review by CBRT personnel concerning management, personnel, office conditions, technical equipment and document and record infrastructure.

An electronic money applicant should therefore expect to demonstrate an operational institution—not simply a company that intends to build one later.

14. When Does the Electronic Money Licence Become Effective?

Where the CBRT concludes that the statutory and regulatory requirements have been satisfied, final approval may be issued.

The final approval specifies which activities are authorised.

The operating licence becomes legally effective upon publication of the relevant CBRT decision in the Official Gazette.

This distinction is important.

Company incorporation does not provide the right to issue electronic money.

Completion of the technology platform does not provide that right.

Submission of the regulatory application does not provide that right.

The regulated activity should only commence after the required authorisation has legally become effective.

15. Licence Fee Following Commencement

A licensed institution must notify the CBRT after beginning operations.

Under the current Regulation, the institution must make this notification within 10 days after commencement of activity.

The notification must include evidence of payment of the TRY 1 million licence fee, together with the relevant statutory financial obligations.

Applicants should therefore budget regulatory fees separately from minimum paid-in capital and minimum own funds.

16. Safeguarding Electronic Money Funds

Protection of customer funds is one of the central principles of electronic money regulation.

Under Law No. 6493, an electronic money issuer must issue electronic money corresponding to the funds it receives.

The law also requires funds collected in exchange for electronic money to be transferred into a separate account at a bank.

The detailed safeguarding rules are contained in the secondary regulations.

Importantly, the rules were amended again in March 2026.

Under the current framework, electronic money issuance funds must be separated from other funds and transferred to the designated electronic money safeguarding account within the applicable regulatory period. The March 2026 amendments also regulate the calculation of the safeguarding-account balance and expressly allow overnight remuneration of the safeguarding account at the bank, subject to the applicable conditions.

The institution must maintain records allowing electronic money funds to be tracked separately, including customer-level tracking subject to the regulatory exceptions.

This means customer funds cannot simply be mixed with ordinary working capital.

An electronic money institution should establish a proper reconciliation system from the beginning.

17. Electronic Money Is Not a Bank Deposit

Electronic money institutions are not ordinary deposit-taking banks.

Article 20 of Law No. 6493 expressly provides that funds received by an electronic money institution in exchange for electronic money are not considered deposits or participation funds for purposes of the Banking Law.

This distinction has important consequences for customer communications.

An EMI should not market its wallet in a way that creates the misleading impression that the customer has opened an ordinary bank deposit account.

Electronic money is a regulated payment product with its own safeguarding framework.

It is not legally identical to a bank deposit.

18. Can Electronic Money Institutions Pay Interest?

No.

Law No. 6493 provides that the issuer may not provide interest or another benefit to the holder based on the period during which the electronic money is held.

This rule becomes particularly important when developing customer-acquisition campaigns.

For example, an electronic money institution should carefully analyse programs that appear to reward customers merely for leaving money in their wallet for a particular period.

Cashback, loyalty and promotional models may involve different legal considerations depending on their structure, but a product should not become a disguised interest-bearing electronic money balance.

19. Can an Electronic Money Institution Grant Loans?

An electronic money institution may not engage in lending activity.

Article 20 of Law No. 6493 expressly prohibits electronic money institutions from providing credit.

This is especially relevant for fintech companies attempting to combine wallets with:

• consumer credit;
• buy-now-pay-later products;
• overdrafts;
• merchant financing;
• salary advances.

Where credit is involved, the structure may need participation from a separately regulated bank or financing company.

The regulatory division of responsibilities should be clearly established.

20. Redemption of Electronic Money

Electronic money holders have important redemption rights.

The current Payment Services Regulation provides that customers may request redemption of some or all of their electronic money.

Subject to applicable statutory obligations, the issuer must process the corresponding refund without delay and, in any event, generally by the end of the business day following receipt of the request.

The regulation also addresses contractual redemption conditions and circumstances in which proportionate redemption fees may be charged.

For fintech product design, this has major practical implications.

A wallet should therefore have a legally compliant cash-out or redemption mechanism.

A business model under which customers can purchase electronic money but cannot reasonably redeem it may create significant regulatory problems.

21. AML and KYC Obligations

Electronic money institutions are part of the regulated Turkish financial ecosystem and are subject to anti-money laundering obligations.

The principal framework arises under Law No. 5549 on Prevention of Laundering Proceeds of Crime and regulations and guidance issued by the Financial Crimes Investigation Board (“MASAK”).

An EMI’s AML framework may include:

• customer identification;
• identity verification;
• beneficial owner identification;
• customer risk classification;
• politically exposed person controls;
• sanctions screening;
• transaction monitoring;
• suspicious transaction reporting;
• enhanced due diligence;
• record retention;
• internal compliance procedures;
• employee training.

These obligations should not be considered something that can be added after the licence is obtained.

AML systems should be integrated into customer onboarding and payment infrastructure before commercial operations begin.

A sophisticated wallet product without functioning transaction-monitoring and KYC infrastructure is not a regulatory-ready electronic money institution.

22. Remote Customer Onboarding

Digital finance businesses frequently acquire customers without physical branches.

Electronic money institutions should therefore establish remote onboarding processes that comply with the applicable Turkish identification, AML and information-security framework.

The onboarding process may need to address:

• identity-document verification;
• authenticity checks;
• customer identity matching;
• fraud-prevention controls;
• security measures;
• sanctions and risk screening;
• retention of required records.

The exact requirements depend on the customer and product structure.

From a compliance perspective, the onboarding journey should be designed together by legal, compliance and technology teams rather than by the product team alone.

23. Personal Data Protection and KVKK Compliance

Electronic money institutions process significant quantities of personal data.

Typical data categories include:

• identity data;
• contact information;
• financial transaction records;
• wallet balances;
• bank-account details;
• device data;
• IP addresses;
• location-related technical information;
• customer-support data;
• fraud indicators.

Therefore, Law No. 6698 on the Protection of Personal Data (“KVKK”) forms an important part of EMI compliance.

In July 2026, the Turkish Data Protection Authority published a dedicated Good Practices Guide on the Protection of Personal Data in the Payment and Electronic Money Sector in cooperation with the Türkiye Payment and Electronic Money Institutions Association.

The guide specifically addresses issues including data-controller and processor roles, personal data processed within the sector, legal bases for processing, personal data transfers, controller obligations and data security.

This is particularly relevant because electronic money institutions routinely combine regulated financial data with sophisticated technology infrastructure.

24. Cross-Border Data Transfers and Cloud Services

International fintech groups commonly use foreign technology providers.

An EMI may rely on:

• cloud hosting;
• fraud detection;
• CRM tools;
• analytics platforms;
• cybersecurity providers;
• global customer-support systems;
• group-company infrastructure.

These arrangements can raise both sector-specific information systems issues and personal data protection questions.

Before entering into such arrangements, a fintech company should determine:

• where customer data will be stored;
• who will have access;
• whether personal data will leave Türkiye;
• whether the provider qualifies as an outsourced service provider;
• whether regulatory approval or special conditions apply;
• whether the infrastructure is compatible with CBRT requirements.

Cloud procurement should therefore be treated as a legal and regulatory decision as well as a technical decision.

25. Information Systems and Cybersecurity

The CBRT maintains a separate regulatory framework governing the information systems of payment and electronic money institutions.

The CBRT’s current payments legislation includes the Communiqué on Information Systems of Payment and Electronic Money Institutions and Data-Sharing Services of Payment Service Providers in the Field of Payment Services.

A regulated EMI should therefore develop robust infrastructure relating to areas including:

• information security governance;
• user authentication;
• privileged access;
• transaction security;
• fraud controls;
• audit logs;
• backup;
• disaster recovery;
• business continuity;
• cybersecurity incident management;
• penetration testing;
• outsourcing;
• database security.

The licensing process itself examines whether the applicant has actually established adequate information systems and operational continuity measures.

This makes technology a central part of the legal licensing project.

26. Record-Keeping Requirements

Law No. 6493 requires payment and electronic money institutions to preserve relevant documents and records for at least 10 years in a secure manner that allows access when required.

The legislation also contains specific requirements relating to information systems and the storage of records within Türkiye.

This requirement should influence:

• database architecture;
• archiving;
• document management;
• cloud configuration;
• outsourcing agreements;
• backup policies.

A fintech company should therefore consider retention rules before finalising its technology architecture.

27. Can an EMI Provide Additional Payment Services?

Yes, provided that the relevant services are included within its authorisation.

The CBRT’s current list of electronic money institutions demonstrates that different EMIs have different permissions under Article 12 of Law No. 6493.

An EMI may therefore potentially combine electronic money issuance with services such as particular forms of:

• payment account operation;
• transfer transactions;
• payment instrument issuance or acceptance;
• money remittance;
• payment initiation;
• account information services,

depending on the scope authorised by the CBRT.

However, an existing licence should not automatically be assumed to cover a new product.

The Payment Services Regulation requires CBRT approval where an authorised institution wishes to expand into a new regulated field.

28. Share Transfers After Licensing

Regulatory approval requirements continue after the company has obtained its licence.

Under Law No. 6493, CBRT approval is required for certain share acquisitions and disposals.

The rules include transactions resulting in a shareholder reaching or crossing thresholds of:

10%, 20%, 33% or 50%.

Certain changes involving privileged shares or changes in control of corporate shareholders may also require approval.

This is particularly important for fintech startups planning multiple investment rounds.

A conventional startup may issue shares rapidly following negotiations with investors.

A regulated EMI cannot necessarily implement investment transactions in the same way without considering CBRT approval requirements.

Regulatory planning should therefore be incorporated into the company’s fundraising strategy.

29. Buying an Existing Electronic Money Institution

Foreign investors sometimes consider acquiring an existing licensed EMI instead of establishing a new institution.

This may appear faster than applying for a completely new licence.

However, an EMI acquisition requires extensive regulatory due diligence.

The purchaser should review at least:

• licence validity;
• authorised activity scope;
• CBRT correspondence;
• past inspections;
• administrative fines;
• AML compliance;
• customer fund safeguarding;
• own-funds position;
• technology infrastructure;
• cybersecurity incidents;
• customer complaints;
• independent audit findings;
• outsourcing;
• shareholder approvals;
• pending regulatory proceedings.

The buyer must also analyse whether the proposed share acquisition itself requires CBRT permission.

Acquiring a licensed company does not merely mean acquiring its regulatory permission.

It also means acquiring its historical compliance risks.

30. Regulatory Enforcement Risk

The Turkish electronic money market is actively supervised.

The CBRT’s January 2026 enforcement announcement provides particularly important evidence of this.

During its 2025 supervision and oversight activities, the CBRT reported that:

• licences of 7 institutions were cancelled;
• licences of 14 institutions were temporarily suspended;
• 12 institutions became subject to prior CBRT approval for dividend distributions;
• administrative fines totalling approximately TRY 373.24 million were imposed on 72 institutions;
• 331 files concerning suspected unauthorised payment-service activities were referred to prosecutors and/or courts.

Current CBRT records also show further licence cancellations affecting electronic money institutions during 2026.

The conclusion is clear:

Obtaining an EMI licence is not the end of regulatory compliance.

It is the beginning of continuous supervision.

31. Operating Without an Electronic Money Licence

Unauthorised activity can create serious consequences.

Law No. 6493 provides criminal sanctions for persons who operate as payment institutions or electronic money institutions without obtaining the required authorisation.

The law provides for imprisonment and judicial fines for unauthorised regulated activity and also sanctions conduct creating the impression of being an authorised institution where the required licence has not been obtained.

For this reason, fintech entrepreneurs should be extremely cautious about strategies such as:

“We will launch first and apply for the licence once the business grows.”

Where real customer funds and regulated services are involved, such an approach may generate significant legal exposure.

32. Practical Electronic Money Licence Checklist

Before applying for an electronic money institution licence in Turkey, investors should ensure that the following issues have been addressed.

Business Model

Determine exactly how the wallet or electronic money product will operate.

Regulatory Classification

Confirm that the product constitutes electronic money and identify any additional payment services.

Company Formation

Establish a compliant Turkish joint-stock company.

Shareholders

Identify direct and indirect shareholders and ultimate beneficial owners.

Capital

Ensure the TRY 5 million statutory paid-in capital requirement is satisfied.

Own Funds

Plan for the TRY 105 million minimum own-funds requirement applicable from 30 June 2026.

Business Plan

Prepare detailed projections, transaction flows and operating procedures.

Management

Appoint appropriate directors and senior management.

Internal Systems

Establish risk management, internal control, accounting and regulatory reporting.

Technology

Build compliant information systems and cybersecurity infrastructure.

Safeguarding

Establish customer fund segregation and electronic money safeguarding accounts.

AML/KYC

Implement customer due diligence, transaction monitoring and suspicious transaction procedures.

KVKK

Establish a comprehensive personal data protection system.

Contracts

Prepare customer agreements, wallet terms, privacy notices and redemption rules.

Operations

Create customer complaint and support processes.

Regulatory Application

Complete the intelligence-review and final-approval stages.

Frequently Asked Questions About Electronic Money Institution Licensing in Turkey

Who regulates electronic money institutions in Turkey?

The Central Bank of the Republic of Türkiye regulates and supervises electronic money institutions under Law No. 6493.

What is the minimum paid-in capital for an electronic money institution?

The statutory minimum paid-in capital is TRY 5 million.

What is the minimum own-funds requirement for an EMI in Turkey in 2026?

As of 30 June 2026, the minimum own-funds requirement is TRY 105 million.

Does an EMI have to be a joint-stock company?

Yes. An electronic money institution must generally be established as a Turkish joint-stock company satisfying the requirements of Article 18 of Law No. 6493.

Can foreigners own an electronic money institution in Turkey?

Foreign investment is possible, but shareholders and persons exercising control must comply with Turkish regulatory requirements. Additional documentation may be required where foreign financial institutions are involved.

Can an electronic money institution pay interest on wallet balances?

No. Electronic money holders cannot be paid interest or provided a benefit based on the period for which electronic money is held.

Can an electronic money institution lend money?

No. Law No. 6493 prohibits electronic money institutions from conducting lending activities.

Can customers redeem electronic money?

Yes. Customers generally have the right to request redemption, and the applicable Regulation contains detailed rules concerning how and when redemption must be processed.

Can an electronic money institution provide payment services?

Yes, but only to the extent that the relevant payment services fall within its CBRT authorisation.

How much is the EMI application fee?

The current Regulation specifies a TRY 500,000 application fee, together with applicable statutory charges.

Is there a licence fee after approval?

Yes. Under the current Regulation, the institution’s commencement notification must include evidence of payment of the TRY 1 million licence fee and applicable statutory obligations.

How long does the final approval stage take?

There is no single guaranteed total licensing period. Following approval of the intelligence-review stage, however, the applicant generally has 120 days to submit its final-approval application, with the possibility of an extension of up to 60 days where justified.

Conclusion: How to Obtain an Electronic Money Institution License in Turkey

Obtaining an electronic money institution license in Turkey is one of the more demanding fintech authorisation processes in the Turkish financial sector.

The process cannot be reduced to company formation.

A prospective EMI must combine:

financial capacity, corporate governance, technology, cybersecurity, customer fund protection, AML/KYC systems, data protection and regulatory compliance.

The first step is always regulatory classification.

Businesses should determine whether their proposed product genuinely involves electronic money issuance. This typically requires analysing whether customer funds are accepted, corresponding monetary value is stored electronically and that value can be used for payment transactions with parties other than the issuer.

Where the model falls within electronic money regulation, the company generally needs to be established as a Turkish joint-stock company and obtain CBRT authorisation before issuing electronic money.

The financial requirements must also be understood correctly.

Although the statutory minimum paid-in capital remains TRY 5 million, the substantially more important minimum own-funds threshold is TRY 105 million as of 30 June 2026.

The licensing process then requires detailed examination of the founders, qualifying shareholders, controllers, management, business plan and financial position.

Following the intelligence-review stage, the applicant must demonstrate that its internal systems and actual infrastructure are operational. This includes internal controls, risk management, accounting, reporting, complaints handling, information systems, cybersecurity and appropriately qualified personnel. The regulatory process may also involve independent examination and an on-site CBRT review.

Customer money is another critical area.

Funds received in exchange for electronic money are subject to specific safeguarding requirements and must be separated from the institution’s ordinary funds. The March 2026 amendments further updated the operation of electronic money safeguarding accounts.

Furthermore, an EMI is not a bank.

It cannot legally use customer electronic money balances as an ordinary deposit-taking business, cannot provide interest based on the holding period and cannot independently conduct lending activity.

Modern EMI compliance also extends well beyond financial licensing.

A Turkish electronic money institution must consider:

• MASAK anti-money laundering requirements;
• customer identification and transaction monitoring;
• Turkish personal data protection law;
• cybersecurity;
• information systems;
• outsourcing;
• customer contracts;
• electronic money redemption;
• regulatory reporting;
• ongoing minimum own funds;
• shareholder changes;
• continuing CBRT supervision.

The regulatory risk of non-compliance should not be underestimated. CBRT enforcement activity during 2025 and 2026 demonstrates that licences may be suspended or cancelled and substantial administrative sanctions may be imposed where regulated institutions fail to satisfy their obligations.

For foreign investors, there is an additional point of particular importance: a foreign electronic money licence should not be treated as an automatic passport into the Turkish market.

A company wishing to issue electronic money in Türkiye should analyse the Turkish regulatory structure independently and determine whether a local licensed entity, acquisition of an existing institution or another legally permissible structure is required.

Businesses considering the establishment of a digital wallet, prepaid payment platform, stored-value product, mobile payment application, embedded finance platform or other electronic money business in Turkey should therefore obtain regulatory advice before launching the product or accepting customer funds.

The most efficient approach is to design the legal structure, transaction flow, safeguarding mechanism, technology architecture and compliance system together from the beginning.

Doing so can significantly reduce regulatory delays, costly product redesigns and licensing risks.

Legal Disclaimer: This article provides general information regarding electronic money institution licensing and fintech regulation in Türkiye as of July 2026. It does not constitute legal advice. Capital requirements, application fees, own-funds thresholds, technical standards and supervisory requirements may change. Each electronic money business model should be analysed individually under the legislation applicable at the relevant time.