Introduction: Is Buy Now Pay Later Regulated in Turkey?

Buy Now Pay Later, commonly abbreviated as BNPL, has become one of the most important products at the intersection of e-commerce, consumer credit and financial technology.

The commercial proposition is simple.

A customer purchases a product immediately but pays the purchase price at a later date or in several instalments.

The merchant receives payment immediately or according to an agreed settlement structure, while the consumer’s payment obligation is deferred.

The model is increasingly attractive to:

• e-commerce platforms;
• online marketplaces;
• retailers;
• fintech companies;
• banks;
• financing companies;
• embedded finance providers.

However, the expression “Buy Now Pay Later” is a commercial expression rather than a standalone legal category under Turkish financial legislation.

As of July 2026, Turkish law does not create a separate financial licence formally called a “BNPL Licence.”

Instead, the regulatory treatment depends on the legal and economic structure of the product.

A BNPL arrangement may, depending on the circumstances, constitute:

• a direct instalment sale by the merchant;
• a consumer credit agreement;
• a financing-company loan;
• a bank loan embedded into checkout;
• a linked credit agreement;
• an embedded finance model involving a regulated lender and a technology intermediary.

The applicable rules can therefore arise from Law No. 6502 on Consumer Protection, the Consumer Credit Agreements Regulation, the Instalment Sales Regulation, Law No. 6361 governing financing companies, banking legislation and Law No. 6493 governing payment and electronic money institutions.

This means the correct regulatory question is not:

“Is BNPL legal in Turkey?”

The correct question is:

Who is actually financing the customer, what economic benefit is received in return, and who carries the credit risk?

These questions determine whether the arrangement is simply a merchant selling its own goods on instalments or whether a regulated financial service is being provided.

This guide explains the principal Buy Now Pay Later regulatory issues in Turkey as of July 2026, including licensing, consumer credit, merchant instalments, financing companies, payment institutions, linked credit, embedded finance, advertising, consumer protection and compliance risks.

1. What Is Buy Now Pay Later?

A typical BNPL model allows the consumer to:

buy now → receive the product immediately → pay later.

Repayment may occur through:

• one deferred payment;
• three or four instalments;
• monthly instalments over a longer period;
• interest-free instalments;
• interest-bearing instalments.

From the consumer’s perspective, these models may look similar.

Legally, however, they can be completely different.

The most important distinction is whether the deferred payment is being offered:

directly by the seller

or

by a separate third-party financing provider.

2. Turkey Does Not Have One Single BNPL Regulatory Regime

Türkiye currently regulates BNPL-type arrangements through existing legal categories rather than through a separate BNPL statute.

A retailer directly selling its own product in instalments can fall within the rules governing instalment sales.

A bank or financing company providing credit for the purchase can fall within consumer credit legislation.

A fintech company that merely integrates the credit product into checkout may instead act as a technology provider or credit intermediary.

A payment or electronic money institution cannot simply transform its payment licence into a lending licence because Law No. 6493 expressly prohibits payment institutions and electronic money institutions from engaging in credit-granting activity.

The legal classification should therefore be completed before the product is marketed.

3. Model One: Merchant-Funded BNPL

The simplest BNPL structure is direct merchant financing.

For example:

A consumer purchases a TRY 12,000 appliance from Retailer A.

Retailer A delivers the product immediately.

The consumer agrees to pay:

• TRY 3,000 today;
• TRY 3,000 next month;
• TRY 3,000 the following month;
• TRY 3,000 in the fourth month.

The merchant itself remains the creditor.

No bank or financing company advances money to the consumer.

This structure can fall within the Turkish instalment sales framework.

The Ministry of Trade defines an instalment sale contract as one under which the seller or service provider undertakes to deliver the goods or perform the service while the consumer pays the price in parts.

Therefore:

Direct merchant BNPL does not automatically mean a separate financial institution licence is required.

However, it remains subject to consumer-protection rules.

4. Instalment Sales Are Still Regulated Consumer Transactions

A merchant should not conclude that an unlicensed merchant-funded BNPL product is therefore “unregulated.”

Consumer instalment sales are specifically regulated.

Among other things, the agreement must be properly documented and provided to the consumer.

The Ministry of Trade states that instalment sale agreements must be established in writing and provided to consumers on paper or through a permanent data storage medium. The contractual text must be clear, understandable and readable.

This creates direct obligations for retailers offering their own “pay in instalments” functionality.

The BNPL checkout should therefore be treated as a contract—not merely a payment-button design.

5. Consumers Have a Seven-Day Withdrawal Right in Instalment Sales

A particularly important difference between direct merchant instalments and consumer credit concerns withdrawal rights.

Under the Turkish instalment-sale regime, consumers generally have:

seven days

to withdraw from an instalment sale contract without giving a reason or paying a penalty, subject to the applicable statutory limitations.

The period generally starts:

• on conclusion of the contract for services;
• on delivery for goods.

The rules include certain exceptions, particularly where goods are used beyond ordinary inspection or where performance of certain services begins with consumer approval.

Therefore, the merchant’s BNPL terms should not simply copy a foreign “Pay in 4” contract.

Turkish statutory withdrawal rules need to be considered separately.

6. Early Payment Rights Apply to Merchant Instalment Sales

A consumer can also pay instalment-sale debt early.

Where the seller or provider has charged interest or commission, the seller must make the appropriate reduction in those amounts according to the early payment.

A merchant therefore cannot create a BNPL contract that states:

“The consumer must pay the full financing charge even if all instalments are paid immediately.”

Such wording may conflict with mandatory consumer rules depending on the structure.

7. Default and Acceleration Are Restricted

Direct merchant BNPL providers should also consider the rules governing acceleration.

Where the seller has reserved the right to demand the entire outstanding balance following default, that right is subject to specific conditions.

For example, the Ministry of Trade explains that the seller’s acceleration right generally requires default involving qualifying instalments and that the consumer must receive at least 30 days’ notice before the accelerated amount is demanded.

A BNPL provider should therefore not automatically convert a single minor late instalment into immediate maturity of the entire purchase price.

8. Model Two: Third-Party BNPL Financing

The regulatory analysis changes significantly when a third party finances the purchase.

Consider:

Consumer buys a TRY 20,000 product from Merchant A.

Fintech Finance Company B pays Merchant A.

Consumer repays Finance Company B in four instalments.

The consumer has received the goods immediately but economically owes a debt to a different entity.

This structure strongly resembles consumer financing rather than a simple instalment sale.

The Ministry of Trade defines a consumer credit agreement as a contract under which the creditor grants or promises credit to the consumer through deferred payment, a loan or similar financing in return for interest, a fee or a similar economic benefit.

That definition is highly relevant to modern BNPL models.

9. Interest-Free Does Not Automatically Mean “Not Credit”

One of the most important misconceptions in the BNPL market is:

“We charge consumers zero interest, therefore we are not providing credit.”

That conclusion is too simplistic under Turkish law.

The statutory consumer-credit concept is not limited to transactions generating traditional interest.

The Ministry of Trade describes consumer credit as including financing provided in return for:

interest, a fee or a similar benefit.

Therefore, a BNPL lender receiving a commercial economic benefit from the arrangement may still require consumer-credit analysis even where the consumer sees “0% interest” on the checkout page.

For example, the lender may earn revenue from:

• merchant fees;
• financing commissions;
• other commercial arrangements.

The precise legal classification should be determined from the full economic structure.

10. Financing Companies Offer a Natural Regulatory Model for BNPL

Türkiye already has a regulated non-bank financing-company sector.

Financing companies operate under Law No. 6361 and BDDK supervision.

The BDDK defines financing-company activity as financing the acquisition of goods or services by making payment directly to the seller on behalf of the natural or legal person purchasing the goods or services, with the borrower later repaying the financing company.

This structure closely resembles a classic checkout BNPL model:

merchant delivers goods → finance company pays merchant → consumer repays finance company.

Accordingly, an international BNPL company entering Türkiye should carefully assess whether its business model falls within the regulated financing-company framework.

11. Financing Companies Pay the Merchant Directly

The BDDK specifically states that financing companies make the credit payment directly to the seller upon delivery or provision of the relevant goods or services, on behalf of the purchaser.

Repayment is then made by the borrower to the financing company.

This is important because it differentiates financing-company BNPL from an ordinary unsecured cash loan.

The financing is tied to the acquisition of a particular product or service.

For e-commerce and embedded finance, this structure can be particularly suitable.

12. Banks Can Also Provide Checkout BNPL

A bank may provide the credit financing an online purchase.

The consumer may experience the process entirely within a merchant or marketplace application, but legally:

• the bank is the creditor;
• the merchant sells the goods;
• the platform may provide the interface.

Turkish Banking as a Service regulation also provides a framework through which non-bank interface providers can allow customers to access banking services provided by a service bank. BDDK’s current legislation continues to include the Digital Banks and Service Model Banking Regulation.

Therefore, embedded BNPL can potentially be structured as:

merchant/platform → service bank → consumer credit.

The commercial platform may own the user experience.

The regulated lender remains the bank.

13. Payment Institutions Cannot Provide BNPL Credit Themselves

This is a critical rule for fintech companies.

Law No. 6493 expressly provides:

a payment institution cannot engage in credit-granting activity.

The same prohibition applies to electronic money institutions.

Therefore, a TCMB payment institution licence does not create authority to launch an independent lending business.

A payment institution cannot simply announce:

“Customers can spend TRY 10,000 today and repay us over four months.”

Where the institution is economically advancing its own funds and taking repayment risk, the model must be reviewed carefully because it can fall within prohibited lending activity.

14. Electronic Money Institutions Cannot Finance Purchases From Their Own Balance Sheet

Electronic money institutions face the same fundamental restriction.

Law No. 6493 provides that electronic money institutions cannot engage in credit-granting activity.

This is important because many BNPL products are integrated into:

• digital wallets;
• prepaid cards;
• payment applications.

An EMI may provide the wallet and payment infrastructure.

But that does not automatically permit the EMI to become the BNPL lender.

A regulated lending partner may therefore need to sit behind the financing function.

15. Payment Institutions Can Still Participate in BNPL Infrastructure

The lending prohibition does not mean payment institutions are irrelevant to BNPL.

A payment institution can potentially provide services such as:

• payment collection;
• merchant acquiring;
• repayment processing;
• payment accounts;
• checkout infrastructure,

provided those services fall within its authorised Article 12 scope.

The TCMB’s current register shows payment institutions’ exact service permissions, including acquiring, payment account services and money-transfer categories.

A BNPL structure may therefore contain both:

a regulated lender

and

a regulated payment service provider.

Those roles should not be confused.

16. Model Three: Fintech Platform as Credit Intermediary

A fintech company may want to operate without carrying the credit risk itself.

For example:

Fintech A integrates several lenders.

Customer chooses “Pay Later.”

Fintech A collects information and submits the application to Bank B or Financing Company C.

Bank B or Financing Company C makes the credit decision and provides the financing.

In such a structure, Fintech A may operate more like a credit intermediary or technology platform rather than the lender.

The Consumer Credit Agreements Regulation recognises the concept of a credit intermediary as a person that offers credit agreements, assists consumers with preparatory work or enters into credit agreements on behalf of the creditor as part of commercial or professional activity.

The contractual and regulatory role of the fintech should therefore be clearly documented.

17. Credit Decisions Should Remain With the Regulated Lender

Where a bank or financing company is the legal creditor, it should retain responsibility for the regulated lending decision.

A technology platform may provide:

• scoring technology;
• customer interface;
• merchant information;
• application data.

However, the architecture should not create a situation where an unlicensed technology company is economically making and funding the credit while the licensed institution merely lends its name.

The regulated financial provider should remain substantively responsible for the credit relationship.

18. BNPL Can Become a “Linked Credit” Agreement

BNPL frequently finances one particular purchase.

That makes the Turkish concept of linked credit (bağlı kredi) particularly important.

The Consumer Credit Agreements Regulation defines linked credit as credit granted exclusively for financing a particular good or service where the credit and purchase agreement form an objective economic unit.

An economic unit can exist where, among other situations:

• the seller finances the credit;
• the third-party creditor uses the seller’s services in preparing or concluding the credit contract;
• the specific goods or services are expressly identified in the credit agreement.

Many checkout BNPL arrangements can potentially display exactly these characteristics.

19. Linked Credit Creates Important Consumer Rights

If the BNPL product qualifies as linked credit, important consequences follow.

Where the consumer validly withdraws from the underlying goods or services contract and provides the relevant notification to the creditor within the applicable withdrawal period, the linked credit agreement can also terminate without penalty.

This has major implications for BNPL system design.

A consumer cancelling an online order should not be forced to continue repaying financing for goods that have been properly returned where the linked-credit rules require the finance arrangement to end.

Merchant, lender and platform systems must therefore communicate effectively.

20. The Lender Can Share Liability With the Merchant

Linked credit also creates an important risk allocation rule.

Where the goods or services are not delivered or are not properly performed, and the consumer exercises qualifying rights such as rescission or price reduction, the seller/service provider and creditor can become jointly liable within the statutory limits.

The Ministry of Trade expressly confirms this principle for linked consumer credit.

For BNPL lenders, merchant due diligence is therefore not purely a fraud issue.

The quality and reliability of merchants can create legal liability.

21. Merchant Quality Becomes a Credit Risk Issue

Traditional credit risk asks:

“Will the borrower repay?”

BNPL requires a second question:

“Will the merchant deliver the goods correctly?”

If the credit and sale qualify as linked agreements, merchant failure can affect the creditor’s legal position.

A serious BNPL lender should therefore review:

• merchant complaints;
• cancellation rates;
• delivery performance;
• refund rates;
• fraudulent merchant behaviour.

Merchant onboarding becomes part of consumer-credit compliance.

22. Consumer Credit Contracts Require Pre-Contractual Information

Where BNPL constitutes consumer credit, the consumer must receive appropriate pre-contractual information.

The Ministry of Trade states that consumer credit agreements must be concluded in writing or at distance and that required information should be provided in clear, understandable and readable form.

The credit agreement framework requires information concerning matters such as:

• type of credit;
• creditor;
• duration;
• total credit amount;
• costs.

The BNPL checkout therefore cannot reduce legally important credit information to an invisible hyperlink simply because the consumer experience is designed to be fast.

23. “One-Click Credit” Still Needs a Valid Contract

BNPL businesses often compete on frictionless checkout.

The customer may expect approval within seconds.

But speed does not eliminate contract requirements.

A digital consumer-credit agreement can be formed at distance, but the creditor still needs to comply with the consumer credit framework. The Ministry of Trade expressly recognises distance consumer credit and applies the statutory credit protections to such contracts.

The correct approach is therefore:

fast onboarding + compliant digital documentation

rather than

fast onboarding instead of documentation.

24. Consumers Generally Have a 14-Day Credit Withdrawal Right

Where BNPL is legally a consumer credit agreement, the consumer generally has:

14 days

to withdraw from the credit agreement without giving a reason and without contractual penalty.

Where the consumer has already used the credit, the consumer generally repays the principal and interest accrued for the period of actual use within the statutory period following the withdrawal notification.

This is separate from the seven-day withdrawal regime applicable to qualifying direct instalment sales.

The distinction again demonstrates why regulatory classification matters.

25. Online Purchase Withdrawal and Credit Withdrawal Are Separate Concepts

A BNPL transaction may involve two contracts:

1. the purchase contract;
2. the financing contract.

For online consumer purchases, distance-sales rules can independently provide withdrawal rights for the underlying purchase, subject to statutory exceptions. The Ministry of Trade states that distance contracts generally provide consumers with a 14-day withdrawal period.

A properly designed BNPL system should therefore determine how:

purchase cancellation

affects

credit cancellation.

Where the arrangement is linked credit, Turkish law provides additional coordination between those contracts.

26. Early Repayment Must Be Reflected in the Credit Cost

Consumer borrowers may repay credit early.

The Ministry of Trade confirms that where a consumer pays all or part of the credit before maturity, the creditor must make the required reduction in interest and other cost elements according to the amount repaid early.

For BNPL, this matters where:

• financing fees;
• interest;
• commissions

are charged.

The consumer should not automatically pay the full scheduled financing cost despite extinguishing the debt early.

27. BNPL Late Fees Cannot Be Designed Without Consumer-Credit Analysis

International BNPL companies often rely heavily on late fees.

In Türkiye, where the BNPL arrangement qualifies as consumer credit, default charges must be analysed within the mandatory consumer-credit rules.

The Consumer Credit Agreements Regulation provides, among other things, that for fixed-term consumer credit the default interest rate cannot exceed the contractual interest rate by more than 30%, and compound interest is prohibited in consumer transactions.

Therefore, a foreign standard clause providing:

“TRY 500 late fee for every missed TRY 1,000 instalment”

cannot simply be imported into Turkish BNPL terms without legal review.

28. Acceleration of Consumer Credit Requires Conditions

Where the creditor reserves the right to demand all outstanding instalments after default, consumer-credit rules restrict the use of that right.

The Ministry of Trade states that acceleration generally requires the creditor to have fulfilled its own obligations, the consumer to have failed to pay at least two consecutive instalments, and the creditor to give at least 30 days’ notice.

A BNPL platform should therefore build collection workflows around Turkish law rather than using automated immediate acceleration after one missed payment.

29. BNPL Advertising Requires Particular Care

BNPL marketing often focuses on messages such as:

• “0% interest”;
• “split your payment”;
• “pay later with no cost.”

These claims must accurately reflect the economic reality.

Turkish consumer advertising rules impose specific transparency requirements for advertising connected to credit.

The Ministry of Trade has expressly strengthened transparency rules for goods or services offered with linked credit, requiring information such as credit term, interest rate, total cost and repayment conditions to be made available in the advertisement or through an appropriate linked disclosure.

BNPL should therefore not be marketed as merely a discount when it is economically credit.

30. “0% Interest” Does Not Mean “0 Cost”

A BNPL product may charge:

• administrative fees;
• transaction fees;
• merchant-funded financing costs;
• default charges.

Marketing should distinguish:

no interest

from

no consumer cost.

Where a consumer credit product has costs, the statutory disclosure framework should be respected.

Misleading presentation can create consumer-law and advertising risk.

31. Merchant-Funded BNPL and Third-Party BNPL Must Be Distinguished Clearly

A retailer may legitimately offer instalment payment itself.

That is different from a checkout button that directs the customer into a loan with Finance Company B.

The consumer should be able to understand:

• who is owed the money;
• whether credit is being provided;
• whether interest or fees apply;
• who handles complaints.

The user interface should not blur the seller and creditor into one undefined “Pay Later” brand.

32. BNPL Through Payment Apps and Wallets

A payment application may want to integrate a BNPL button.

This can be legally viable where the roles are properly divided.

For example:

Wallet Company A → payment service

Bank B → credit

Merchant C → seller

The consumer receives financing from Bank B, while Wallet Company A handles the payment interface.

The wallet’s payment licence does not itself become a lending licence because payment and electronic money institutions are prohibited from granting credit.

Contracts and branding should reflect the distinction.

33. Embedded BNPL Under Banking as a Service

BNPL can also be delivered as an embedded banking product.

A retailer or marketplace may act as the customer-facing interface while a service bank provides the credit.

Türkiye maintains a formal Banking as a Service framework under the Digital Banks and Service Model Banking Regulation.

This creates a structured route for non-financial companies to integrate regulated banking products without themselves becoming banks.

However, the underlying bank remains the regulated lender.

34. Foreign BNPL Companies Entering Turkey

A foreign BNPL provider should not assume that a licence or exemption in another jurisdiction applies automatically in Türkiye.

The Turkish structure must be analysed independently.

Possible market-entry options include:

Working With a Turkish Bank

The bank provides the consumer credit while the foreign BNPL business supplies technology and merchant integration.

Working With a Turkish Financing Company

The financing company pays merchants and collects repayments from customers under Law No. 6361.

Establishing or Acquiring a Regulated Financial Business

Where appropriate, a foreign investor may establish or acquire the relevant regulated institution, subject to the applicable approval framework.

The right structure depends on who wishes to carry:

• credit risk;
• customer relationship;
• merchant settlement;
• funding responsibility.

35. A Foreign “Pay in 4” Model Should Not Simply Be Copied

Global BNPL models often depend on local regulatory exemptions.

Türkiye should be analysed on its own terms.

An overseas arrangement may be structured as:

• short-term interest-free credit;
• merchant-funded credit;
• deferred-payment credit;
• card-based instalments.

Turkish classification can differ.

The commercial term “Pay in 4” has no special statutory meaning.

The legal analysis should always identify:

seller → lender → customer → money flow → repayment.

36. Can an E-Commerce Marketplace Become a BNPL Lender?

A marketplace should be cautious before financing buyers itself.

Where the marketplace simply allows the seller to receive the purchase price in instalments, the structure may potentially fit merchant/seller financing depending on the contractual arrangement.

But where the marketplace independently pays sellers and becomes creditor to consumers across third-party merchant transactions, it can move toward regulated credit or financing activity.

A marketplace is not automatically authorised to lend merely because the credit is connected to e-commerce.

37. Merchant Fee Revenue Is Important to Regulatory Analysis

Many BNPL companies do not charge consumers interest.

Instead, they charge the merchant a percentage of the purchase price.

That commercial structure does not automatically remove credit regulation.

Because the consumer-credit definition extends to credit granted in return for interest, fees or similar economic benefits, the existence of merchant-paid consideration should form part of the classification analysis.

The final answer depends on the exact contractual and economic structure.

Founders should therefore avoid legal analyses based only on the statement:

“The customer pays no interest.”

38. BNPL Funding Structure Matters

A BNPL company also needs to determine whose capital funds merchant payments.

Possibilities include:

• the merchant’s own deferred receivable;
• a bank;
• financing company;
• another authorised lender.

A technology company using its own balance sheet to systematically pay merchants and create consumer receivables can face a fundamentally different regulatory analysis from a company merely routing applications to licensed lenders.

Funding is therefore one of the strongest indicators of the true economic role.

39. Assignment of BNPL Receivables

BNPL businesses may also sell or assign receivables for funding purposes.

Such structures can raise questions relating to:

• assignment law;
• factoring;
• securitisation;
• consumer rights.

A company should therefore review the entire lifecycle of the receivable, not only origination.

If the fintech originates consumer debt and immediately sells it to another institution, that fact does not necessarily eliminate regulatory concerns relating to how the debt was originally created.

40. Consumer Credit Scoring and Automated Decisions

Modern BNPL frequently relies on instant automated credit assessment.

Platforms may use:

• transaction history;
• device data;
• shopping behaviour;
• income information;
• previous repayment behaviour.

This creates significant issues concerning:

• data protection;
• fairness;
• explainability;
• information security.

A lender should have a lawful basis for processing data used in credit assessment and should avoid collecting excessive information merely because technology makes collection possible.

41. KVKK Applies to BNPL

BNPL requires extensive personal data processing.

Information may include:

• identity data;
• credit application information;
• repayment history;
• merchant purchases;
• transaction data;
• device information;
• fraud indicators.

Where the BNPL provider and merchant or platform share customer information, responsibilities under Law No. 6698 on the Protection of Personal Data (“KVKK”) should be mapped carefully.

The distinction between:

• lender;
• marketplace;
• payment provider;
• scoring vendor

can determine whether a party acts as controller, processor or a separate controller for different processing activities.

42. Shopping History Can Reveal More Than Credit Risk

BNPL providers embedded inside retail applications can access unusually rich consumer data.

A platform may know:

• what the customer buys;
• how often;
• how much;
• whether products are returned.

That information may help assess risk.

But credit assessment does not automatically justify unlimited reuse of the same information for unrelated marketing or profiling.

Data minimisation and purpose limitation should therefore be considered from the beginning.

43. AML/KYC Depends on the Regulated Provider

Where BNPL is provided by a bank or financing company, financial-sector customer identification and AML requirements become relevant.

The precise compliance obligations depend on the regulated provider and product architecture.

A technology platform collecting customer data on behalf of the lender should provide the lender with sufficient access and evidence to meet its legal obligations.

Outsourcing onboarding does not eliminate the regulated institution’s compliance responsibility.

44. BNPL and Consumer Over-Indebtedness

Although Turkish law does not presently create a standalone BNPL-specific responsible-lending code under that name, ordinary credit and consumer-protection requirements continue to matter.

A provider should not deliberately design the interface to obscure the fact that the customer is taking on debt.

Risky design choices may include:

• displaying instalment amount much more prominently than total debt;
• hiding fees until the final screen;
• automatically preselecting BNPL;
• suggesting that credit is equivalent to a discount.

BNPL may be technologically frictionless.

Debt is still debt.

45. Consumer Complaint and Dispute Resolution

BNPL disputes can concern:

• unauthorized credit;
• undelivered goods;
• refunds;
• incorrect instalments;
• early repayment;
• fees.

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

Disputes below that value fall within the Consumer Arbitration Committee framework, while disputes at or above the threshold proceed through the applicable mediation and consumer-court process.

BNPL providers should therefore maintain effective local complaint procedures.

46. BNPL and Refunds

Refund architecture is one of the most difficult operational issues.

Suppose:

Customer buys a product for TRY 12,000 through BNPL.

Lender has already paid Merchant A.

Customer returns the product.

Merchant issues a refund.

The platform must ensure that:

• the consumer does not continue paying cancelled financing;
• the merchant’s liability is reconciled;
• the lender’s records are corrected.

Where the financing constitutes linked credit, Turkish consumer law provides specific interaction between cancellation of the purchase and the credit agreement.

Payment and lending systems should therefore be integrated at the legal as well as technical level.

47. BNPL Merchant Agreements

A lender working with merchants should use detailed merchant agreements.

The agreement should address:

Merchant Eligibility

Which businesses can offer BNPL?

Customer Disclosures

Who displays legally required credit information?

Sale Data

Which information must the merchant transmit?

Refunds

How are returned goods handled?

Fraud

Who bears fraudulent transaction losses?

Customer Complaints

Which complaints go to the merchant and which to the lender?

Linked Credit Liability

How will statutory consumer claims be handled?

The merchant contract should not attempt to transfer mandatory consumer-law liabilities in a way that prejudices the consumer.

48. BNPL Technology Agreements

Where a separate fintech provides BNPL technology to a bank or financing company, the technology agreement should address:

• regulatory roles;
• onboarding;
• credit decisioning;
• data sharing;
• cybersecurity;
• service availability;
• audit rights;
• complaints;
• business continuity.

The technology provider should also ensure branding does not create the false impression that it is the regulated creditor where it is not.

49. BNPL M&A Due Diligence

Investors considering a Turkish BNPL company should conduct regulatory due diligence before relying on growth metrics.

Important questions include:

Who Is the Creditor?

Merchant, bank, financing company or fintech?

Who Funds the Purchase?

Identify the source of capital.

Does the Fintech Carry Credit Risk?

This can reveal the true regulatory position.

Are Payment or EMI Licences Being Misused?

Payment and electronic money institutions cannot lend.

Are Consumer Credit Agreements Valid?

Check documentation and pre-contract information.

Are Credit and Sale Linked?

This can create joint liability.

How Are Refunds Managed?

Operational failures can create large consumer liabilities.

How Are Late Fees Calculated?

Review mandatory consumer-credit limits.

How Is Customer Data Used?

Review credit scoring and marketing data.

A BNPL target with rapid GMV growth may nevertheless carry serious regulatory exposure if its creditor structure is incorrect.

50. Common BNPL Regulatory Mistakes in Turkey

“BNPL Is Interest-Free, So It Is Not Credit”

Not necessarily.

The Turkish consumer-credit concept refers to financing provided for interest, fees or similar benefits—not interest alone.

“A Payment Institution Can Provide BNPL”

A payment institution cannot itself conduct credit-granting activity.

“An EMI Can Finance Wallet Purchases”

Electronic money institutions are also prohibited from credit-granting activity.

“The Merchant Can Never Offer Instalments Without a Licence”

Too broad.

A merchant selling its own goods or services with payment in instalments can fall within the consumer instalment-sale regime rather than automatically becoming a financing company.

“All Pay-in-4 Products Are Legally the Same”

Incorrect.

The classification depends on who is the creditor and how the arrangement is funded.

“If the Customer Returns the Goods, the Credit Continues Automatically”

Linked credit rules can cause the financing agreement to terminate or create joint liability in qualifying circumstances.

“One Missed Instalment Makes the Entire Debt Immediately Due”

Consumer credit and instalment sale regimes impose conditions and notice requirements before acceleration.

“BNPL Can Be Marketed as Free Even When There Are Other Charges”

Marketing should reflect the actual cost and legally required credit disclosures.

Practical BNPL Compliance Checklist for Turkey

Before launching a Buy Now Pay Later product in Türkiye, founders should answer the following questions.

Who Sells the Product?

Identify the merchant.

Who Is the Creditor?

Merchant, bank, financing company or another entity?

Who Funds the Purchase?

This is one of the most important regulatory questions.

Is It a Direct Instalment Sale?

If yes, review the instalment-sales framework.

Is It Consumer Credit?

Analyse whether payment is deferred or financing is provided for interest, fee or similar benefit.

Is a Financing Company Involved?

If so, ensure the structure matches Law No. 6361 and BDDK requirements.

Is a Bank the Lender?

Confirm credit documentation and embedded-finance architecture.

Is a Payment Institution Involved?

Ensure it provides payments only within its licence scope and is not granting the credit.

Is an EMI Involved?

The EMI should not become the lender.

Is the Credit Linked to a Particular Purchase?

Analyse the linked-credit rules.

Are Required Disclosures Provided?

Total amount, fees, repayment terms and creditor details should be clear.

Is Withdrawal Properly Managed?

Distinguish seven-day instalment-sale rights from 14-day consumer-credit rights and applicable distance-sale rights.

Are Early Payments Reflected Correctly?

Required cost reductions should be processed.

Are Default Charges Lawful?

Review default-interest and acceleration restrictions.

Are Refunds Integrated?

Product return and credit cancellation systems must communicate.

Is Marketing Accurate?

“0% interest” must not hide other material costs.

Is Customer Data Used Lawfully?

Review credit scoring, profiling and data sharing.

Is the Actual Lender Visible?

Embedded branding should not obscure the regulated creditor.

Frequently Asked Questions About BNPL Regulation in Turkey

Is BNPL regulated in Turkey?

BNPL is not currently regulated through a single standalone “BNPL Law.” Instead, the applicable regime depends on whether the product is an instalment sale, consumer credit, bank credit, financing-company product or another structure.

Is there a BNPL licence in Turkey?

There is no separate licence formally called a BNPL licence.

Where the model constitutes regulated financing, the provider may need to be a bank, financing company or other appropriately authorised lender depending on the precise structure.

Can a retailer offer Buy Now Pay Later directly?

Potentially yes.

A retailer may sell its own goods or services under an instalment-sale arrangement, subject to Turkish consumer-law requirements.

Does a direct merchant instalment sale require a financing-company licence?

Not automatically.

The distinction depends on whether the merchant is simply deferring payment for its own sale or operating a broader independent financing business.

Can a payment institution offer BNPL?

A payment institution cannot engage in credit-granting activity under Law No. 6493. It may participate in payment processing but should not become the lender.

Can an electronic money institution provide BNPL credit?

An electronic money institution is also prohibited from credit-granting activity.

Can a financing company provide BNPL?

A financing company provides financing for purchases by paying the seller directly on behalf of the purchaser and receiving repayments from the borrower. This structure can closely correspond to checkout financing or BNPL.

Is zero-interest BNPL automatically outside consumer credit rules?

No automatic conclusion can be drawn solely from a zero-interest label. Turkish consumer-credit rules refer to financing in return for interest, fees or similar benefits.

What is a linked credit agreement?

It is consumer credit granted exclusively for financing a particular good or service where the credit agreement and purchase form an economic unit.

What happens if goods purchased through linked BNPL are not delivered?

In qualifying linked-credit circumstances, the seller/service provider and creditor can be jointly liable for specified consumer remedies within statutory limits.

Is there a withdrawal right for consumer credit?

Yes. Consumers generally have 14 days to withdraw from a consumer credit agreement without giving a reason or paying a contractual penalty.

What is the withdrawal period for direct instalment sales?

The Ministry of Trade states that qualifying instalment-sale contracts generally provide consumers with a seven-day withdrawal right, subject to applicable exceptions.

Can consumers repay BNPL early?

Where the product constitutes consumer credit, early repayment requires the appropriate reduction in interest and other cost elements. Direct instalment sales with interest or commission also contain early-payment protections.

Can a BNPL lender accelerate all payments after one missed instalment?

Not automatically. Consumer-credit and instalment-sale regulations contain conditions and notice requirements before acceleration can occur.

Can a marketplace provide BNPL itself?

It depends on whether the marketplace is simply facilitating merchant instalments or independently providing and funding credit. Where it becomes the actual lender, separate banking/financing regulation may become relevant.

Can BNPL be offered through Banking as a Service?

Potentially. Türkiye has a formal Service Model Banking framework, enabling non-bank interfaces to distribute banking services supplied by banks. The bank remains the regulated banking provider.

What is the Consumer Arbitration Committee threshold in 2026?

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

Conclusion: Is BNPL a Regulated Financial Service in Turkey?

The correct answer is:

Sometimes yes, sometimes no—the result depends on who actually provides the financing.

This is the most important principle in Buy Now Pay Later regulation in Turkey.

Turkish legislation does not currently create a standalone licence named:

BNPL Licence.

Instead, the legal analysis begins by separating commercial terminology from the underlying transaction.

A merchant may directly sell its own products in instalments.

That arrangement can fall within the Turkish instalment-sale framework.

The Ministry of Trade defines an instalment sale as a contract under which the seller delivers the goods or service and the consumer pays the price in parts.

Such a merchant does not automatically become a financing company simply because the checkout page says:

“Buy Now Pay Later.”

However, the merchant still faces mandatory consumer protections.

The contract must be properly documented.

Consumers can benefit from statutory withdrawal rights, early-payment protections and restrictions concerning default and acceleration.

The position changes substantially when a third party enters the transaction.

Where Finance Company B pays Merchant A and the consumer repays Finance Company B, the arrangement begins to resemble regulated consumer financing.

The BDDK’s own description of financing-company activity is highly relevant: financing companies finance purchases by paying the seller directly on behalf of the purchaser, and the borrower then repays the financing company.

That structure is extremely close to the commercial mechanics of many international BNPL models.

Banks can also provide BNPL-style checkout credit.

The merchant or technology platform can embed the product into its application, while the bank remains the regulated lender.

Türkiye’s Banking as a Service framework creates additional opportunities for embedding such banking products into non-bank platforms.

For fintech founders, one rule is particularly important:

A payment institution licence is not a lending licence.

Law No. 6493 expressly prohibits payment institutions from granting credit.

The same rule applies to electronic money institutions.

This means a payment company may participate in the BNPL payment chain but should not automatically carry the financing exposure itself.

A possible lawful architecture can therefore be:

consumer → merchant/platform → regulated lender → payment service provider.

The lender provides the credit.

The payment institution processes the financial movement.

The platform provides the user experience.

When these roles are clearly separated, embedded BNPL can be structured more safely.

The opposite structure is risky:

fintech uses its own funds → merchant is paid immediately → consumer repays fintech later → fintech claims it is only a payment company.

A payment licence does not eliminate the economic reality of credit.

Another critical issue is the meaning of “interest-free.”

Many BNPL businesses describe themselves as non-credit products because the customer pays zero interest.

Turkish consumer law requires a more sophisticated analysis.

The Ministry of Trade defines consumer credit by reference to financing granted in return for interest, fees or similar economic benefits.

Therefore:

“0% interest” is not, by itself, a complete regulatory exemption.

Merchant-funded fees, platform commissions and other economic benefits should be considered in the legal analysis.

Where BNPL constitutes consumer credit, extensive consumer protections become relevant.

The consumer generally receives a 14-day right of withdrawal from the credit agreement.

The consumer has early-repayment rights requiring reductions in interest and other cost elements.

Default interest and acceleration are regulated.

The creditor cannot simply impose unlimited late fees or automatically demand the entire balance after one missed instalment.

These requirements should be designed into the technology.

A BNPL platform should not treat compliance as a PDF produced after the checkout system has already been built.

The payment schedule, refund logic, default engine and notifications should all reflect the legal rules.

Linked credit is another particularly important area.

Many BNPL arrangements are used to finance one specific purchase.

Turkish consumer legislation defines linked credit in precisely that context: credit provided exclusively for a particular good or service where the sale and credit agreements form an economic unit.

When the rules apply, the lender’s relationship with the merchant creates additional obligations.

If the goods are never delivered or are defective and the consumer exercises qualifying remedies, the lender can share liability with the merchant within the statutory framework.

This means merchant underwriting should form part of BNPL risk management.

The lender should not examine only:

consumer creditworthiness.

It should also examine:

merchant quality.

Refunds require the same integrated approach.

A consumer who properly returns goods should not remain trapped in a financing schedule because the merchant system and BNPL system do not communicate.

For linked credit, cancellation of the sale can directly affect the financing arrangement.

This makes API design a legal compliance matter.

Consumer communication is equally important.

A BNPL provider should clearly identify:

• the seller;
• the creditor;
• total purchase price;
• instalment amounts;
• financing cost;
• due dates;
• default consequences.

Marketing claims should also be reviewed carefully.

The Ministry of Trade has strengthened disclosure expectations for advertising involving linked credit, including information concerning credit term, interest and total cost.

An advertisement saying:

“Buy today for only TRY 999 per month”

while hiding the actual total debt can create obvious consumer-protection concerns.

For foreign BNPL companies entering Türkiye, the strategic options will therefore generally involve one of the following:

partner with a Turkish bank;

partner with an authorised Turkish financing company;

operate as a technology or credit-intermediation layer while the licensed lender retains the credit function;

or

establish or acquire the necessary regulated financial institution where the business case justifies it.

The correct option depends primarily on one issue:

Who wants to carry the credit risk?

If the foreign BNPL company wants merely to provide technology, merchant acquisition and customer experience, a licensed Turkish lender can remain responsible for the financing.

If the BNPL company itself intends to pay merchants, create consumer receivables and earn financing returns, the regulatory analysis becomes substantially more demanding.

For investors, this distinction is equally important.

A BNPL company may describe itself as a “payments fintech.”

That description should never replace legal due diligence.

The investor should identify:

who advances the funds → who books the receivable → who collects repayments → who absorbs default losses.

Those four questions will often reveal the true legal nature of the business much more accurately than the company’s marketing terminology.

Data protection must also form part of the architecture.

BNPL underwriting increasingly relies on shopping and behavioural information.

The fact that a platform can analyse a customer’s purchase history does not necessarily mean all data can be used for every purpose.

Credit assessment, fraud management and advertising can involve separate processing purposes and should be analysed under KVKK accordingly.

Finally, customer disputes should be anticipated.

In 2026, consumer disputes below TRY 186,000 are within the monetary scope of the Consumer Arbitration Committees.

For a high-volume BNPL company, even small systemic contractual problems can therefore generate large numbers of consumer claims.

The recommended legal sequence for a BNPL launch in Türkiye is:

identify seller → identify lender → map funding → determine instalment sale vs consumer credit → identify licence → determine linked-credit status → prepare consumer disclosures → build withdrawal/refund logic → structure default and collections → review advertising → implement KYC/data controls → launch.

The central regulatory principle can therefore be summarised as follows:

BNPL is not regulated because it is called “Buy Now Pay Later.” It becomes regulated according to the legal substance of who grants the customer time to pay and who assumes the financial risk.

A retailer deferring payment on its own sale, a financing company paying a merchant, a bank offering checkout credit and a payment institution processing the repayment may all appear to the consumer as the same “Pay Later” button.

Under Turkish law, they are not the same transaction.

Understanding that distinction is the foundation of a legally sustainable BNPL business in Türkiye.

Legal Disclaimer: This publication provides general information concerning Buy Now Pay Later, instalment sales, consumer credit, financing companies, payment institutions and embedded finance in Türkiye as of July 2026. It does not constitute legal, financial, tax or regulatory advice. BNPL is a commercial expression rather than a standalone Turkish legal category. Regulatory classification depends on the precise creditor, source of funding, merchant relationship, repayment model, fees, payment infrastructure and consumer contract. Each BNPL business model should therefore be individually reviewed under Law No. 6502, Law No. 6361, Law No. 6493, banking legislation and the applicable secondary regulations before launch.