Introduction: Are Prepaid Cards Regulated in Turkey?

Yes.

Prepaid cards can fall within one of the most heavily regulated areas of Turkish fintech law because a prepaid card may simultaneously constitute:

• a payment instrument;
• electronic money;
• a payment account-related product;
• a card-based payment instrument;
• an AML/KYC risk product.

However, not every card loaded with money is regulated in exactly the same way.

The legal classification depends principally on where the card can be used, who accepts it, whether customer value is electronically stored, whether the card is linked to an identified customer and whether the balance can be transferred or withdrawn.

A closed-loop gift card usable only within one retailer’s own stores can have a substantially different regulatory status from a general-purpose prepaid card accepted through a nationwide card scheme.

Likewise, an anonymous prepaid card subject to very low transaction limits operates under a different AML framework from a fully identified reloadable prepaid card.

The principal legislation is Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions, together with the Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers.

The Central Bank of the Republic of Türkiye (“CBRT” or “TCMB”) regulates payment and electronic money institutions. The CBRT’s current register confirms that all authorised electronic money institutions may issue electronic money under Article 18(2) of Law No. 6493, although the additional payment services they may provide depend on their individual licence scopes.

For fintech companies, the most important question is therefore not simply:

“Can we issue a prepaid card?”

The correct questions are:

Does the prepaid value constitute electronic money?

Does the issuer need an electronic money institution licence?

Does a closed-loop exemption apply?

Can the card be issued anonymously?

Which MASAK limits apply?

What refund and consumer rights must be provided?

This guide explains the principal prepaid card licensing, AML and consumer protection requirements in Turkey as of July 2026.

1. What Is a Prepaid Instrument Under Turkish Law?

The Payment Services Regulation defines a prepaid instrument broadly as a physical or non-physical payment instrument where the customer pays funds to the issuer before making expenditure and can then use an equivalent amount of funds for payment services.

The definition is technology-neutral.

Accordingly, a prepaid instrument can potentially take the form of:

• a physical prepaid card;
• a virtual prepaid card;
• an app-based payment instrument;
• another electronically accessible instrument.

The commercial name of the product is not decisive.

A fintech calling its product:

• “gift balance”;
• “shopping credit”;
• “cash card”;
• “digital prepaid balance”

does not determine the legal classification.

The regulatory analysis follows the substance of the value stored and the payment functionality provided.

2. What Is Electronic Money?

Electronic money is a central concept for prepaid card regulation.

The CBRT describes electronic money as monetary value that:

• is issued against funds received by the issuer;
• is stored electronically;
• is used for payment transactions under Law No. 6493;
• is accepted as a payment instrument by persons other than the issuer.

This means that a general-purpose prepaid card loaded with customer money and accepted by unrelated merchants will frequently operate as an electronic money product.

A typical structure is:

Customer pays TRY 5,000 → issuer creates TRY 5,000 electronic balance → customer spends balance at third-party merchants.

That structure contains the core elements associated with electronic money.

3. When Does a Prepaid Card Require an Electronic Money Licence?

The Payment Services Regulation provides an especially important rule.

Except where the statutory limited-network exemption applies, where a payment instrument is used at merchants and the payment amount is transferred through the institution that issued the instrument, the issuer must be authorised to issue electronic money under Article 18(2) of Law No. 6493.

For a fintech startup, this has major consequences.

A company cannot normally issue a general-purpose prepaid card accepted at unrelated merchants merely by obtaining ordinary corporate registration.

The regulated activity may require:

an electronic money institution licence from the CBRT.

This changes:

• company structure;
• regulatory capital;
• governance;
• information systems;
• AML obligations;
• safeguarding requirements.

4. Which Authorisations Are Required for Prepaid Electronic Money?

The CBRT’s Business Models Guide provides useful clarification.

Because electronic money accounts are generally treated as payment accounts—except for anonymous prepaid instruments—the CBRT states that a non-anonymous electronic money model generally requires authorisation under:

• Article 12(1)(a), concerning payment account-related services;
• Article 12(1)(c);
• Article 18(2), electronic money issuance.

Additional licences may also be necessary depending on the functionality.

For example, where the prepaid instrument can be used to make money transfers, Article 12(1)(b) and/or Article 12(1)(ç) may also become relevant. If bill payments are enabled, the corresponding bill-payment authorisation may be necessary.

This produces a fundamental principle:

A prepaid card licence should be built around the functions of the card, not merely the fact that it is prepaid.

5. Payment Institutions Cannot Automatically Issue General-Purpose Prepaid E-Money Cards

Payment institutions and electronic money institutions are not interchangeable.

The CBRT’s Business Models Guide recognises that a payment institution can issue certain payment instruments without holding electronic money issuance authority where the product is used for specified payment-account or transfer functions and cannot be used for purchases at merchants.

Once reusable prepaid value can be spent at third-party merchants, however, electronic money becomes a central licensing question.

A fintech should therefore be cautious about trying to structure a merchant-spendable prepaid card through an ordinary payment institution licence alone.

6. 2026 Minimum Own Funds for an Electronic Money Institution

The financial requirements are substantial.

The CBRT increased minimum own-funds requirements effective 30 June 2026.

The current amounts are:

• TRY 20 million for the specified bill-payment institution category;
• TRY 40 million for other payment institutions, excluding the separate pure Account Information Service category;
• TRY 105 million for electronic money institutions.

Therefore, a fintech whose prepaid card constitutes electronic money should generally build its business plan around at least the TRY 105 million regulatory own-funds floor, subject to the complete own-funds calculation rules.

7. TRY 105 Million Is Not Necessarily the Maximum Capital Requirement

The headline minimum should not be mistaken for a fixed maximum.

The current prudential framework also requires an electronic money institution to maintain own funds based on its electronic money liabilities, and additional payment-service activity can generate further own-funds calculations.

The Regulation provides that an electronic money institution must maintain own funds amounting to 2% of its average outstanding electronic money liability, while additional payment-service activities can trigger separate calculations.

The CBRT also retains regulatory powers to increase certain calculated requirements following risk assessment.

A rapidly growing prepaid card company may therefore need capital materially above TRY 105 million.

8. Closed-Loop Prepaid Cards: The Most Important Exemption

Not every prepaid card requires an electronic money licence.

Law No. 6493 contains an important exemption for certain prepaid instruments operating within a restricted environment.

The Payment Services Regulation explains that a prepaid instrument can remain outside the general electronic-money framework where it is genuinely usable only:

• in a particular store; or
• within a specific store network.

This is generally referred to as the:

closed-loop or limited-network exemption.

Typical products requiring analysis under this rule can include:

• retailer gift cards;
• campus cards;
• fuel-network cards;
• employee benefit cards;
• restricted entertainment cards.

9. A Closed-Loop Card Must Be Genuinely Limited

The exemption should not be interpreted broadly.

The Regulation expressly states that a prepaid instrument does not qualify for the limited-network treatment merely because the issuer enters into agreements with merchants.

A product designed to be accepted by all merchants added to the issuer’s network, or one issued to be compatible with card-scheme organisations under Law No. 5464, cannot rely on the statutory limited-network exemption merely by calling itself a closed-loop card.

This is a crucial distinction.

Consider two products.

Product A — Retailer Gift Card

The card is accepted only in Brand A’s stores and its genuine store network.

The closed-loop exemption may potentially apply.

Product B — Prepaid Shopping Card

The issuer signs contracts with thousands of unrelated merchants.

The card operates through a conventional card network and can be used broadly.

This structure is much more likely to fall within regulated electronic money.

10. Franchise Networks Can Require Special Analysis

Limited-network structures can become complex where franchisees are involved.

The CBRT’s guidance recognises that transfers relating to prepaid instruments within an issuer’s own qualifying store network can remain relevant to the limited-network analysis, including franchise-style structures.

However, the network should remain genuinely connected to the limited commercial ecosystem.

A company cannot simply call thousands of unrelated businesses “network merchants” and expect the closed-loop exemption to apply indefinitely.

11. Large Closed-Loop Models Can Still Attract CBRT Reporting

Businesses operating within statutory payment-service exclusions should also review the specific reporting regime applicable to certain excluded models.

The current CBRT framework includes notification obligations where specified excluded activities become sufficiently large, allowing the regulator to assess the scale and impact of the model.

This reflects an important regulatory principle:

An exemption should be monitored as the business grows.

A small retailer gift-card programme and a nationwide multi-merchant prepaid ecosystem should not automatically be treated as presenting identical regulatory risks.

12. What Is an Anonymous Prepaid Card?

Turkish regulation specifically recognises anonymous prepaid instruments.

The Payment Services Regulation defines an anonymous prepaid instrument as a prepaid instrument that:

• is not linked to a payment account;
• is issued without identification or identity verification;
• falls within the monetary limits specified by MASAK;
• can be reloadable or non-reloadable;
• allows spending only up to the loaded balance.

Anonymous prepaid products therefore occupy a special position.

They are not unrestricted anonymous financial accounts.

Their use is heavily restricted.

13. Current MASAK Limits for Anonymous Prepaid Cards

The current consolidated MASAK General Communiqué No. 5 provides simplified identification treatment for qualifying prepaid cards.

For a non-reloadable single-use prepaid card, the loaded amount must not exceed:

TRY 2,750.

For a reloadable prepaid card, both:

• total loading within one month; and
• the card balance at any time

must not exceed:

TRY 2,750.

These limits are highly significant.

A fintech should not assume it can distribute anonymous prepaid cards with ordinary commercial limits of TRY 20,000 or TRY 50,000.

Above the simplified-treatment perimeter, ordinary customer-identification rules become relevant.

14. Anonymous Cards Cannot Be Designed as Money Transfer Products

The current MASAK treatment expressly requires qualifying anonymous prepaid cards not to be usable for fund transfers.

They are intended principally for restricted payment use rather than anonymous person-to-person money movement.

This distinction is fundamental.

A product allowing:

Anonymous Card A → Anonymous Card B

to transfer money would create a substantially higher AML risk and cannot safely be treated like a low-value anonymous shopping card.

A fintech seeking peer-to-peer transfer functionality should expect identified customer relationships and a more extensive licence/AML framework.

15. Where Can Anonymous Prepaid Cards Be Used?

The current Payment Services Regulation significantly restricts anonymous instruments.

Anonymous prepaid instruments can be used for:

• payments where the cardholder is physically present at the merchant and the instrument is physically used;
• purchases from qualifying e-commerce service providers/intermediaries holding the relevant Turkish Trust Seal (Güven Damgası);
• bill payments.

The institution must implement measures ensuring compliance with these restrictions.

The regulation therefore does not support anonymous general-purpose digital wallets that can be freely used anywhere online.

16. Anonymous Does Not Mean Unregulated

This is one of the most common misunderstandings.

An “anonymous prepaid card” is not outside financial regulation.

Rather, it is a specifically recognised low-value product subject to restricted functionality and simplified identity-treatment rules.

The issuer still operates within the regulated payment/electronic-money system where the underlying product constitutes electronic money.

The institution must still manage:

• AML risk;
• transaction limits;
• fraud;
• cybersecurity;
• suspicious transaction detection.

A customer not being fully identified does not eliminate the issuer’s compliance obligations.

17. Multiple Anonymous Cards Can Create AML Risk

Fintech companies should also avoid a purely card-by-card compliance mentality.

A customer attempting to purchase or use numerous anonymous prepaid cards can potentially circumvent monetary limits economically even where each individual instrument remains below the regulatory ceiling.

MASAK’s general risk-based AML principles remain relevant.

Institutions should consider controls capable of identifying:

• repeated card purchases;
• linked devices;
• recurring telephone numbers;
• abnormal merchant behaviour;
• suspicious loading patterns.

Simplified measures should never become a tool for deliberate circumvention of AML rules.

18. Identified Prepaid Cards Can Offer Broader Functionality

Where the customer is properly identified, the card can potentially be designed with broader features, subject to the issuer’s licence.

Depending on regulatory authorisation, a full-service prepaid product may provide:

• merchant payments;
• payment account functionality;
• money transfers;
• bill payment;
• ATM or cash-related functions;
• digital wallet integration.

Each additional feature should be mapped against the Article 12 payment-service categories.

The CBRT’s Business Models Guide expressly states that enabling transfer of prepaid electronic money can require additional Article 12(1)(b) and/or 12(1)(ç) authority.

19. Prepaid Cards for Minors

Turkish regulation specifically addresses prepaid products issued to persons under legal age.

Except for anonymous prepaid instruments, when a prepaid instrument is first issued to a minor, the issuer must obtain the consent of the minor’s legal representative.

The consent must be recorded and appropriate procedures must be created.

This makes prepaid cards potentially suitable for:

• youth cards;
• family spending cards;
• student products,

but requires the issuer to build parental/legal-representative controls into the product.

20. Parents Must Be Able to Monitor Minor Card Spending

The regulation goes further than merely requiring initial consent.

For non-anonymous prepaid cards provided to minors, the institution must develop mechanisms allowing the legal representative whose consent was obtained to monitor expenditure and must make those mechanisms available when requested.

A youth prepaid card should therefore consider functions such as:

• spending history;
• parental dashboard;
• transaction notifications;
• card controls.

This is a good example of legal requirements directly shaping fintech product design.

21. Electronic Money Must Be Issued Without Delay

Where funds are paid to obtain electronic money, the institution must issue electronic money corresponding to the funds received without delay.

The Regulation treats electronic money as issued at the moment payment is made for the purpose of obtaining it.

The issuer must also provide the customer with a receipt, electronically or on paper, showing the amount of funds received in exchange for electronic money.

A prepaid balance should therefore reconcile precisely with customer funding.

22. The Issuer Cannot Pay Interest on the Prepaid Balance

Electronic money is not a bank deposit.

The Regulation expressly prohibits interest from being accrued on funds received in exchange for electronic money.

It also prohibits providing a customer with a benefit linked to:

• the length of time electronic money is held; or
• the amount held.

For example, a prepaid card issuer should not structure its product as:

“Keep TRY 100,000 on your prepaid card for six months and earn 8%.”

That begins to resemble deposit or investment activity rather than regulated electronic money.

23. Loyalty Rewards Must Be Distinguished From Interest

The prohibition does not necessarily mean every promotional benefit is unlawful.

Fintech companies may operate:

• merchant discounts;
• cashback campaigns;
• loyalty programmes.

However, the reward should not economically amount to interest based on how much prepaid money the customer holds and for how long.

The distinction should be analysed carefully.

A merchant-funded cashback on a purchase is conceptually different from paying a return merely because funds remain stored in the customer’s prepaid balance.

24. Consumers Have a Right to Redeem Electronic Money

One of the strongest consumer protections applicable to prepaid electronic money is the right to redemption.

The Payment Services Regulation expressly provides that the customer may request redemption of some or all of the electronic money balance.

The issuer must process the corresponding repayment:

• without delay; and
• in every case no later than the end of the next business day after receiving the request,

subject to other legally authorised restrictions.

This is highly important for prepaid cards.

A regulated issuer cannot simply say:

“Loaded balances are never refundable.”

25. How Can Prepaid Electronic Money Be Redeemed?

The Regulation allows redemption through conversion of the electronic money into forms including:

• banknotes;
• coins;
• book money;
• electronic money issued by another institution,

depending on the customer’s preference and applicable rules.

The customer agreement should explain the redemption process clearly.

The issuer should also maintain operational systems capable of processing redemption requests efficiently.

26. A Prepaid Card Can Have an Expiry Date—but There Are Rules

The agreement may provide an expiry date for electronic money.

However, the expiry period cannot be set at less than:

one year.

This prevents issuers from imposing extremely short expiry periods that economically confiscate unused balances.

Customers must also be informed of the contractual terms before entering into the agreement.

27. Redemption Fees Are Restricted

An electronic money issuer cannot impose unlimited redemption fees.

A proportionate fee may be charged only under the circumstances specified by the Regulation and where the fee is clearly provided for in the contract.

These situations include certain requests:

• before termination of the agreement;
• before an agreed expiry date;
• more than one year after the expiry date.

The fee must be proportionate to the cost of the redemption operation.

Accordingly, an arbitrary “50% balance redemption fee” would create serious regulatory concerns.

28. Credit Card-Funded Electronic Money Must Generally Be Refunded to the Same Card

A particularly important anti-fraud rule applies where the customer purchased electronic money using a credit card.

In that situation, redemption must generally be made back to the same credit-card account.

This reduces the ability to use a prepaid product as a mechanism for:

credit card → electronic money → unrelated bank account

fund extraction.

Where the relevant card has already been cancelled, the Regulation provides alternative treatment in specified circumstances.

29. Low-Value Prepaid Instruments Receive Simplified Contract Treatment

The Payment Services Regulation contains special rules for low-value instruments.

Where the instrument has a spending limit of TRY 2,750 or less, or cannot contain more than TRY 2,750 at any time, simplified information and contractual rules can apply.

For qualifying instruments, the parties may agree to reduced information requirements, and in specified circumstances a full framework agreement under Article 41 is not mandatory.

This reflects the principle of proportionality.

A TRY 500 gift-style payment instrument does not necessarily need the same contractual infrastructure as a high-limit full-service electronic money account.

30. Low-Value Treatment Does Not Eliminate Mandatory Consumer Protection

Simplification does not mean complete deregulation.

Even for low-value products, the provider must continue to provide essential information concerning matters such as:

• how the instrument is used;
• liability;
• relevant fees;
• basic characteristics of the service.

Where transaction-by-transaction information cannot technically be provided because the customer is unidentified, the provider must still make information concerning the available balance accessible.

31. Unauthorized Prepaid Card Transactions

Identified prepaid cards may also fall within the broader payment-services rules governing unauthorized transactions.

The customer is generally required to notify the payment service provider without delay after becoming aware of an unauthorized or incorrectly executed payment transaction.

The general correction period is:

13 months after the payment transaction.

Where the provider failed to supply the legally required transaction information, the customer may not be bound by the ordinary 13-month period.

This is particularly important for prepaid card disputes involving:

• stolen credentials;
• fraudulent card usage;
• account takeover.

32. Lost or Stolen Prepaid Cards

The Regulation also establishes a limited customer liability rule for qualifying unauthorized transactions arising from a lost or stolen payment instrument or failure to protect security information.

The payer can generally be responsible for up to:

TRY 250

of unauthorized losses occurring during the 24 hours before notification.

After notification, the customer generally cannot be held responsible for subsequent unauthorized transactions, subject to fraud and other statutory exceptions.

Card-blocking functionality should therefore be readily accessible.

33. Anonymous Low-Value Instruments Can Have Different Liability Rules

The standard unauthorized-payment framework does not operate identically for every low-value or anonymous payment instrument.

Article 73 permits certain different arrangements where:

• the payment instrument cannot be blocked;
• the customer is unidentified;
• technical characteristics make ordinary authorization proof impracticable.

This is another reason consumers should understand the difference between:

anonymous low-value prepaid card, and

fully identified prepaid account/card.

The latter generally provides a richer customer relationship and security structure.

34. Complaint Handling

Payment service providers must maintain effective complaint processes.

The Payment Services Regulation requires payment service providers to respond to payment-service complaints and objections within:

20 days

after the application.

The response must be reasoned, demonstrable and provided using the customer’s application method. The provider must also make it easy for customers to reach the relevant complaint-handling unit.

A prepaid card issuer should therefore maintain accessible:

• mobile support;
• written complaint channels;
• transaction-dispute procedures.

35. Consumer Protection Law Also Applies

Payment regulation does not eliminate Türkiye’s general consumer protection framework.

The Ministry of Trade continues to list Law No. 6502 on Consumer Protection and secondary legislation including:

• unfair contract terms;
• distance financial services;
• commercial advertising and unfair commercial practices;

within the current consumer legislation framework.

Prepaid card issuers dealing with consumers should therefore avoid:

• hidden fees;
• misleading marketing;
• disproportionate termination clauses;
• unfair expiry provisions.

Financial regulation and consumer law operate together.

36. Consumer Arbitration Committee Threshold for 2026

For 2026, consumer disputes with a value below:

TRY 186,000

fall within the monetary jurisdiction of the Consumer Arbitration Committees under the current annual threshold.

This can cover prepaid-card disputes involving matters such as:

• withheld balance;
• disputed fees;
• failed refunds;
• unauthorized transactions.

Higher-value disputes may proceed through the relevant consumer dispute and court mechanisms, subject to applicable procedural requirements.

37. MASAK Compliance for Prepaid Card Issuers

Electronic money institutions are obliged entities under Türkiye’s anti-money laundering framework.

A prepaid card issuer should therefore maintain AML controls covering:

• customer identification;
• beneficial ownership where relevant;
• PEP screening;
• sanctions screening;
• transaction monitoring;
• suspicious transaction reporting;
• record retention.

Anonymous prepaid instruments are a limited simplified-treatment category, not an AML exemption.

The current MASAK General Communiqué No. 5 expressly ties the simplified regime to monetary and functional restrictions.

38. Reloading Patterns Must Be Monitored

Prepaid products can be used to fragment financial activity.

A customer may attempt to:

• purchase many cards;
• repeatedly reload cards just below thresholds;
• use related devices or contact information;
• distribute cards to other persons.

A robust AML system should identify patterns rather than treating every card as entirely unrelated.

This is particularly important because criminals may attempt to exploit the low-value anonymous regime by structuring activity below regulatory thresholds.

39. Suspicious Transaction Reporting Still Applies

Where suspicious circumstances arise, simplified identification rules do not prevent the institution from investigating and reporting suspicious activity.

A prepaid card provider should have red flags addressing matters such as:

• repeated purchases of anonymous cards;
• abnormal loading activity;
• unusual merchant use;
• card farming;
• suspicious geographic patterns.

AML thresholds should never be interpreted as a guaranteed safe harbour for suspicious behaviour.

40. Prepaid Cards and KVKK

Identified prepaid card programmes process significant personal data.

This may include:

• identity information;
• contact information;
• payment records;
• card usage history;
• device information;
• fraud data;
• KYC records.

In July 2026, the Turkish Personal Data Protection Authority and TÖDEB published a dedicated Good Practices Guide on Personal Data Protection in the Payment and Electronic Money Sector.

The Guide covers:

• controller/processor relationships;
• processing grounds;
• personal data transfers;
• data-controller obligations;
• data security.

Prepaid card issuers should therefore operate a sector-specific KVKK compliance programme rather than relying on a generic privacy policy.

41. Prepaid Card Data Can Be Highly Sensitive From a Fraud Perspective

Cardholder information can allow criminals to:

• take over customer accounts;
• impersonate customers;
• execute unauthorized payments.

The Payment Services Regulation separately recognises sensitive customer data used for authentication or payment instructions.

The institution should therefore use controls such as:

• encryption;
• access restrictions;
• secure authentication;
• fraud monitoring;
• transaction logging.

Cybersecurity is a financial regulatory obligation, not merely an IT preference.

42. Physical and Virtual Prepaid Cards

The prepaid instrument definition is broad enough to accommodate both physical and virtual models.

The important legal questions remain the same:

• Is monetary value prepaid?
• Is it electronically stored?
• Where can it be spent?
• Who accepts it?
• Can it be transferred?
• Is the customer identified?

A virtual card is not automatically less regulated merely because no plastic card exists.

The regulator follows the payment function.

43. Gift Cards vs Prepaid Cards

The expression gift card can create confusion.

A genuine retailer-specific gift card may potentially fall within the closed-loop exemption.

A broadly accepted prepaid card marketed as a “gift card” can instead constitute regulated electronic money.

The correct classification should therefore examine:

acceptance network + stored value + issuer relationship + payment flow.

The marketing name should be ignored when performing the legal analysis.

44. Employee Benefit and Meal Cards

Employee benefit cards, meal cards and similar products can also require careful regulatory classification.

Where the instrument is strictly restricted to:

• a defined category of goods;
• a genuinely limited network,

a limited-purpose exemption may potentially be relevant.

Where the instrument gradually becomes usable at a wide range of unrelated merchants for general spending, the legal position can change.

Product expansion should therefore trigger a new regulatory-perimeter analysis.

45. International Card Schemes

A prepaid card designed to operate through general card-scheme infrastructure creates particular regulatory implications.

The current Payment Services Regulation expressly states that instruments issued to be compatible with card-system organisations under Law No. 5464 do not qualify for the closed-loop exemption merely on the basis of being prepaid.

This is especially relevant for:

• Visa prepaid products;
• Mastercard prepaid products;
• similarly structured general-purpose card products.

Such products should generally be analysed as regulated payment/electronic money instruments rather than ordinary retailer gift cards.

46. Foreign Prepaid Card Companies Entering Turkey

A foreign prepaid-card issuer should not assume that its overseas e-money or payment licence automatically authorises Turkish issuance.

A foreign fintech planning to offer cards to Turkish residents should determine:

• who legally issues the electronic money;
• who contracts with the customer;
• which entity holds the balance;
• whether a Turkish regulated issuer is required;
• how customer data is processed.

Possible structures include:

• establishing a Turkish EMI;
• acquiring a Turkish EMI;
• partnering with an authorised Turkish institution while remaining genuinely technical or commercial.

Foreign licence status does not eliminate Turkish regulatory analysis.

47. Prepaid Card M&A Due Diligence

Investors acquiring a Turkish prepaid card company should review at least:

Licence

Does the target hold electronic money issuance authority?

Payment-Service Scope

Does its licence cover all features of the prepaid card?

Closed-Loop Claims

Does any allegedly exempt product genuinely satisfy the limited-network conditions?

Anonymous Cards

Do loading limits and usage restrictions comply with current MASAK requirements?

Capital

Does the EMI maintain the current TRY 105 million minimum and additional calculated own funds?

Safeguarding

Do customer electronic-money balances reconcile with protected funds?

Redemption

Can customers obtain balance refunds within the regulatory timetable?

AML

Are anonymous and identified products properly monitored?

Minors

Are parental-consent and monitoring procedures operational?

KVKK

Is cardholder data lawfully processed?

Cybersecurity

Have material card or account security incidents occurred?

Regulatory weakness can materially change the value of a prepaid-card business.

48. Common Prepaid Card Compliance Mistakes

“It Is a Gift Card, Therefore No Licence Is Required”

Incorrect.

The actual acceptance network determines whether the closed-loop exemption is available.

“Every Prepaid Card Is Electronic Money”

Not necessarily.

A genuine closed-loop product can potentially fall outside the electronic-money regime.

“Anonymous Means No KYC Rules”

Incorrect.

Anonymous instruments are permitted only within tightly restricted monetary and functional limits.

“We Can Set Any Anonymous Card Limit We Want”

No.

The current MASAK simplified-treatment limits include the TRY 2,750 thresholds described above.

“Anonymous Cards Can Be Used for P2P Transfers”

The simplified anonymous regime does not permit fund-transfer functionality.

“Loaded Money Is Non-Refundable”

For regulated electronic money, customers generally have statutory redemption rights.

“We Can Pay Interest on Unused Balances”

Electronic money issuers cannot pay interest or a holding-period/amount-dependent benefit.

“The EMI Only Needs TRY 5 Million”

That confuses statutory application-stage capital concepts with current ongoing prudential requirements.

From 30 June 2026, the headline minimum own-funds requirement for an electronic money institution is TRY 105 million.

Practical Prepaid Card Compliance Checklist for Turkey

Before launching a prepaid card in Türkiye, management should answer the following questions.

Product Classification

Does the instrument store prepaid monetary value?

Acceptance Network

Can it be used only in the issuer’s own network, or at unrelated third-party merchants?

Electronic Money

Does the product satisfy the definition of electronic money?

Licence

Does the issuer hold Article 18(2) electronic money authority?

Additional Permissions

Does the product also support transfers, bill payments or payment accounts?

Closed Loop

Is the network genuinely limited?

Card Scheme

Is the instrument compatible with a general card system?

Anonymous Product

Will customers be identified?

MASAK Limits

If anonymous, do the TRY 2,750 loading/balance limits and usage restrictions apply correctly?

Fund Transfers

Is P2P transfer disabled for anonymous instruments?

Minors

Are legal-representative consent and monitoring mechanisms available?

Redemption

Can customers redeem electronic money within the regulatory timeframe?

Expiry

Is any expiry period at least one year?

Interest

Does the product avoid paying a return based on balance and holding period?

Capital

Does the EMI satisfy the TRY 105 million minimum and applicable additional calculations?

AML

Are loading and spending patterns monitored?

Consumer Protection

Are fees and conditions transparent?

KVKK

Is cardholder data processed and transferred lawfully?

Security

Can customers immediately block an identified lost or compromised instrument?

Frequently Asked Questions About Prepaid Cards in Turkey

Are prepaid cards regulated in Turkey?

Yes. Depending on their structure, prepaid cards can fall within the payment instrument and electronic money framework regulated by the CBRT.

Is every prepaid card electronic money?

No. A genuinely limited closed-loop product may potentially fall within the statutory exemption. General-purpose cards accepted by third-party merchants will more commonly require electronic-money analysis.

Who can issue electronic money in Turkey?

Banks, authorised electronic money institutions and PTT within the statutory framework may issue electronic money. The CBRT confirms that all institutions on its authorised EMI register hold Article 18(2) authority.

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

From 30 June 2026, the minimum is TRY 105 million, subject to the full prudential calculation framework.

Can a retailer issue its own gift card without an EMI licence?

Potentially, where the product genuinely satisfies the limited-network/closed-loop exemption. Broad merchant acceptance or general card-scheme compatibility can remove the product from that exemption.

What is an anonymous prepaid card?

It is a qualifying prepaid instrument not linked to a payment account and issued without customer identification or verification within the MASAK monetary limits.

What is the current anonymous prepaid card limit?

Under the current MASAK General Communiqué No. 5, the relevant simplified limits are TRY 2,750 for qualifying single-use cards and TRY 2,750 monthly loading and maximum balance for qualifying reloadable cards.

Can anonymous prepaid cards transfer money?

The simplified anonymous regime requires that the instruments not be usable for fund transfers.

Can anonymous prepaid cards be used online?

Their use is restricted. The Regulation allows specified transactions including purchases through qualifying e-commerce providers holding the Turkish Trust Seal, together with physical merchant use and bill payments.

Can prepaid cards be issued to minors?

Yes, but for non-anonymous instruments the legal representative’s consent must be obtained and recorded when the card is initially issued.

Do parents have a right to monitor a minor’s prepaid card?

The issuer must develop functionality allowing the relevant legal representative to monitor spending and provide that functionality where requested.

Can an EMI pay interest on prepaid card balances?

No. Interest cannot accrue on funds received in exchange for electronic money, and benefits cannot be tied to how long or how much electronic money is held.

Can the customer request unused prepaid balance back?

Yes, where the balance constitutes electronic money. The customer can request redemption of some or all of the balance.

How quickly must electronic money be redeemed?

The issuer must process redemption without delay and no later than the end of the next business day after receiving the request, subject to applicable legal restrictions.

Can a prepaid card have an expiry date?

Yes, but the agreed electronic-money expiry period cannot be less than one year.

Can a redemption fee be charged?

Only in the circumstances permitted by the Regulation, where provided in the contract, and the fee must be proportionate to the cost.

How long can a consumer dispute an unauthorized payment?

The general correction period is 13 months from the payment transaction, subject to the regulatory exceptions.

How quickly must prepaid card complaints be answered?

Payment-service complaints and objections must generally receive a reasoned and demonstrable response within 20 days.

What is the Consumer Arbitration Committee threshold in 2026?

For 2026, disputes below TRY 186,000 fall within the current monetary threshold for Consumer Arbitration Committee applications.

Conclusion: How to Structure a Prepaid Card Legally in Turkey

The regulation of prepaid cards in Turkey begins with one central question:

What does the customer actually receive when money is loaded onto the card?

Where the customer pays funds to an issuer, receives equivalent electronically stored monetary value and can use that value with third-party merchants, the product will generally need to be analysed as electronic money.

The CBRT’s regulatory definition of electronic money focuses on value issued against funds, electronically stored and accepted by persons other than the issuer.

For general-purpose prepaid products, this usually means an electronic money institution becomes the appropriate regulatory architecture.

The CBRT’s Business Models Guide confirms that non-anonymous electronic-money products generally require a combination of electronic-money authority and relevant Article 12 payment-service permissions. Additional functionality can expand the required licence further.

A prepaid card enabling transfers, for example, cannot be analysed only as a merchant-spending product.

The transfer functionality may itself require additional payment-service authorisation.

The limited-network exemption nevertheless creates important room for genuinely restricted prepaid products.

A retailer can potentially operate a prepaid card within a particular store or qualifying store network without converting the product into general-purpose electronic money.

But the limitation must be real.

The Payment Services Regulation expressly rejects attempts to treat broad merchant networks or cards compatible with general card-scheme infrastructure as exempt merely because the issuer labels them closed loop.

This is especially important for startups considering a “gift card marketplace.”

The more merchants and unrelated categories the product supports, the more difficult it becomes to argue that the payment instrument remains genuinely limited.

Anonymous prepaid cards form another important—but narrow—part of the market.

Turkish law does allow certain low-value prepaid instruments to be issued without ordinary customer identification.

However, anonymous prepaid instruments should not be confused with unrestricted anonymous financial accounts.

The current MASAK framework sets the relevant qualifying limits at TRY 2,750 for a non-reloadable single-use instrument and, for qualifying reloadable cards, TRY 2,750 for monthly loading and the maximum balance.

The functionality is also restricted.

Anonymous prepaid instruments cannot use the simplified regime to provide fund-transfer services and can only be used within specified payment scenarios, including qualifying physical merchant transactions, approved Trust Seal e-commerce environments and bill payments.

Consequently, a fintech should not design an anonymous product first and attempt to impose regulatory limitations later.

The limitations should be coded directly into the architecture.

The system should technically prevent:

• excess loading;
• prohibited transfers;
• non-permitted online use.

This is particularly important because AML regulation focuses on substance.

Repeated use of numerous low-value instruments can still create suspicious behaviour requiring investigation.

The electronic money rules also create significant consumer protection.

Customers can request redemption of all or part of their electronic money and the issuer must generally complete the repayment no later than the end of the next business day.

This makes statements such as:

“All prepaid balances are final and non-refundable”

particularly risky for regulated electronic money products.

Expiry provisions are also restricted.

The contract may establish an electronic-money expiry date, but it cannot be shorter than one year. Redemption fees are only permitted in specified circumstances and must remain proportionate to the actual cost.

A further important distinction concerns the economic nature of electronic money.

An electronic money institution cannot pay interest or offer a benefit based simply on the amount and period for which the customer keeps money on the prepaid card.

Electronic money is designed as a payment product, not an investment or savings product.

Fintech companies developing loyalty programmes must therefore distinguish ordinary merchant incentives from a return economically equivalent to interest.

Prepaid cards issued to minors require further product controls.

Except for anonymous instruments, legal-representative consent is required during initial issuance, and the issuer must establish mechanisms allowing the representative to monitor spending when requested.

For youth fintech products, compliance therefore becomes part of the user interface.

Parental controls are not merely a desirable commercial feature—they are directly connected with the regulatory framework.

Financial capacity represents another major entry barrier.

From 30 June 2026, electronic money institutions are subject to a headline minimum own-funds requirement of TRY 105 million.

The regulatory calculation does not necessarily end there.

Electronic money institutions must also consider their average outstanding e-money liability and any additional payment-service activity.

For investors, this means a prepaid-card company should be valued based not only on customers and transaction volume but also on the capital needed to maintain regulatory compliance.

Consumer protection adds another layer.

Identified prepaid card users generally benefit from payment-services protections concerning unauthorized transactions.

A customer can ordinarily seek correction within 13 months after an unauthorized or incorrectly executed payment.

Where a card or security information is lost or stolen, the customer generally bears only up to TRY 250 of qualifying unauthorized losses occurring during the 24 hours before notification, subject to fraud, intentional conduct and other statutory exceptions.

Payment providers must also respond to payment-service complaints within 20 days.

In addition, general Turkish consumer law remains relevant.

The Ministry of Trade’s current 2026 legislation continues to include Law No. 6502 together with unfair-terms, advertising and related consumer regulations.

For consumer disputes, the 2026 Consumer Arbitration Committee threshold is TRY 186,000.

Data protection and cybersecurity must likewise be built into the prepaid-card model.

The July 2026 KVKK/TÖDEB Payment and Electronic Money Sector Good Practices Guide specifically addresses the personal information processed by payment and electronic money businesses and provides guidance on data-controller roles, processing conditions, transfers and security.

For an identified prepaid-card business, the company may hold:

• identity information;
• complete payment histories;
• device data;
• transaction-monitoring indicators;
• KYC documents.

That information has significant financial value and fraud sensitivity.

For foreign fintech companies considering Türkiye, the practical market-entry choice will generally involve:

establishing a Turkish EMI, acquiring an existing authorised EMI, or partnering with an authorised Turkish institution while ensuring the regulated issuer remains responsible for the financial product.

The correct solution depends on whether the foreign company wants control over:

• card issuance;
• electronic money;
• customer balances;
• merchant acceptance;
• KYC;
• settlement.

The recommended regulatory sequence for a prepaid card project is therefore:

define the acceptance network → determine whether the closed-loop exemption applies → determine whether value constitutes electronic money → identify anonymous vs identified model → map card functionality → identify Article 12 permissions → establish EMI structure where required → calculate capital → build MASAK controls → prepare redemption and consumer terms → implement KVKK/cybersecurity → obtain CBRT authorisation → launch.

The central principle can be summarised simply:

In Turkey, the legal status of a prepaid card depends less on what the card is called and more on where it can be used, how the value is stored and what the holder can do with the money.

A tightly restricted retailer gift card can sit outside the full electronic-money framework.

A nationwide reloadable card accepted through a general card network is a fundamentally different financial product.

An anonymous TRY 2,750 card is different again from an identified customer account supporting transfers and cash functions.

Understanding those distinctions before product development can determine whether a prepaid-card project requires a relatively simple closed-loop structure or a fully licensed TRY 105 million-own-funds electronic money institution.

For founders, investors and international card companies, that regulatory classification should therefore be completed before the product is marketed to Turkish customers.

Legal Disclaimer: This publication provides general information concerning prepaid cards, prepaid payment instruments and electronic money regulation in Türkiye as of July 2026. It does not constitute legal, financial, tax or regulatory advice. The classification of a prepaid product depends on its acceptance network, loading limits, customer identification model, payment functions, transfer functionality, cash features and card-scheme infrastructure. MASAK monetary thresholds and CBRT prudential requirements may also change. Each prepaid-card business model should therefore be individually analysed under Law No. 6493, current CBRT regulations, MASAK legislation, consumer law and KVKK before launch.