Introduction: Are Alternative Lending Platforms Legal in Turkey?

Alternative lending has become one of the most important branches of modern financial technology.

Instead of requiring every borrower to obtain credit through a conventional bank branch, digital platforms increasingly connect borrowers with:

• banks;
• financing companies;
• institutional investors;
• private investors;
• crowdfunding investors;
• alternative finance providers.

Commercial models may be described as:

• Peer-to-Peer Lending (P2P Lending);
• Marketplace Lending;
• Digital Lending;
• Alternative Lending;
• Embedded Lending;
• Revenue-Based Financing;
• Merchant Cash Advance;
• Debt Crowdfunding.

However, Turkish law does not currently provide one general financial licence called an “Alternative Lending Platform Licence” or “P2P Lending Licence.”

Instead, the regulatory classification depends on what the platform actually does.

The critical questions are:

Who provides the money?

Who legally becomes the creditor?

Does the platform itself fund loans?

Does the platform collect money from investors?

Does it issue or facilitate securities?

Does it hold borrower or investor funds?

Does it merely provide technology to an authorised lender?

Depending on the answers, the business may fall within the jurisdiction of:

• the Banking Regulation and Supervision Agency (“BRSA” or “BDDK”);
• the Capital Markets Board of Türkiye (“CMB” or “SPK”);
• the Central Bank of the Republic of Türkiye (“CBRT” or “TCMB”);
• MASAK;
• the Ministry of Trade;
• the Turkish Personal Data Protection Authority.

BDDK currently supervises banks as well as non-bank financial institutions including financing, factoring, financial leasing and savings-financing companies.

The CBRT separately regulates payment and electronic money institutions under Law No. 6493.

Meanwhile, the SPK regulates crowdfunding platforms and expressly recognises both equity-based and debt-based crowdfunding under the Crowdfunding Communiqué No. III-35/A.2.

Therefore, the first rule for founders and investors is straightforward:

“Alternative lending” is a commercial category, not a regulatory exemption.

A digital interface can modernise lending.

It cannot eliminate the licensing rules applying to the underlying financial activity.

1. What Is an Alternative Lending Platform?

An alternative lending platform is generally a digital business that facilitates financing outside the traditional branch-based bank-loan model.

The platform may:

• collect borrower applications;
• conduct digital onboarding;
• analyse financial information;
• calculate credit scores;
• match borrowers with lenders;
• display financing offers;
• facilitate contract execution;
• process repayments;
• provide servicing technology.

However, these functions can be structured in very different ways.

A platform may be only a technology intermediary.

Another platform may itself fund every loan.

A third may collect money from investors and allocate that money to borrowers.

A fourth may operate through a licensed financing company.

These models do not have the same regulatory treatment.

2. There Is No Standalone P2P Lending Licence in Turkey

Türkiye should not be approached on the assumption that the UK, US or EU terminology for marketplace lending applies automatically.

There is presently no general Turkish licence category titled:

Peer-to-Peer Lending Institution

or

Marketplace Lending Institution.

Instead, the legal structure must fit into an existing Turkish financial-law category.

Possible regulated routes include:

• bank lending;
• financing-company lending;
• debt-based crowdfunding;
• factoring for qualifying receivables;
• properly structured technology intermediation.

A platform that does not fit within an available category should not assume that the absence of a statute using the words “P2P Lending” means the activity is unrestricted.

3. Model One: Platform as Pure Technology Provider

The lowest regulatory-risk alternative lending structure generally involves a fintech that does not lend money itself.

For example:

Fintech Platform A provides:

• digital onboarding;
• comparison tools;
• credit-scoring software;
• application APIs.

Bank B or Financing Company C:

• makes the lending decision;
• signs the credit agreement;
• funds the borrower;
• owns the receivable;
• carries default risk.

The platform can therefore be deeply involved technologically without becoming the creditor.

This distinction is similar to other Turkish fintech models: regulation generally follows the entity performing the legally regulated financial function rather than the company providing software around that function.

4. Technology Provider vs Actual Lender

Founders should focus on economic substance.

A fintech moves closer to being an actual lender where it:

• uses its own capital to finance customers;
• determines who receives credit;
• determines the credit amount;
• earns the financing return;
• records the loan receivable;
• bears customer default losses.

The following structure is therefore fundamentally different:

Fintech A pays TRY 100,000 to borrower → borrower owes Fintech A TRY 120,000 later.

Calling Fintech A a “marketplace” does not necessarily change the underlying economic reality.

The legal analysis should ask who is the creditor—not what the mobile application is called.

5. Banks Are the Traditional Digital Lending Route

Banks can provide loans digitally within their authorised banking activities.

A fintech can therefore build an alternative lending interface around a bank.

For example:

Borrower → Fintech Application → Bank → Loan

The fintech may provide:

• user experience;
• application technology;
• data analysis;
• customer acquisition.

The bank can remain responsible for:

• credit underwriting;
• final approval;
• funding;
• the credit contract;
• regulatory lending obligations.

This structure allows an alternative lending platform to operate without attempting to become an unauthorised bank.

6. Financing Companies Are a Key Non-Bank Lending Route

Türkiye has an established regulated financing-company sector under Law No. 6361.

BDDK explains that a financing agreement is a structure under which the purchase of goods or services is financed by making payment directly to the seller on behalf of the purchaser, after which the purchaser repays the financing company.

This model can be especially relevant to:

• e-commerce finance;
• checkout finance;
• automotive finance;
• merchant-linked lending;
• certain BNPL products;
• embedded lending.

Financing companies are supervised by BDDK and form a separate category of authorised non-bank financial institutions.

Accordingly, a fintech that wants to operate purchase financing at scale can consider partnering with an authorised financing company rather than lending directly from an ordinary technology company.

7. A Financing Company Licence Is Not Merely a Software Registration

A company cannot become a regulated financing company simply by adding lending to its articles of association.

Financial institutions under Law No. 6361 operate within a BDDK licensing, supervision and enforcement framework. BDDK has expressly emphasised that activities regulated under banking, card, leasing, factoring and financing legislation require the necessary regulatory permissions and that unauthorised activity may lead to legal proceedings.

Therefore, founders should choose between:

technology company + regulated financing partner

and

becoming/acquiring an appropriately licensed financial institution.

Those are materially different projects.

8. Model Two: Marketplace Lending With Multiple Regulated Lenders

A marketplace may aggregate credit offers from several banks or financing companies.

For example:

Customer enters financing requirements.

Platform sends the application to:

• Bank A;
• Bank B;
• Financing Company C.

The platform displays available offers.

The customer selects one.

The chosen regulated creditor provides the loan.

This model can provide genuine comparison and marketplace functionality without requiring the platform itself to finance borrowers.

However, contracts and customer communications should identify clearly:

• the actual creditor;
• credit terms;
• responsibility for complaints;
• whether the platform receives a commission.

The platform should not create the impression that it is itself authorised to extend credit if it is not.

9. Model Three: Balance-Sheet Lending by the Fintech

A different model exists where the technology company funds loans from its own balance sheet.

This creates substantially greater regulatory risk.

A company repeatedly providing financing to customers as a professional business cannot assume that ordinary corporate capacity alone is sufficient merely because the lending occurs online.

Turkish financial regulation contains dedicated categories for banks and non-bank finance institutions, and BDDK publicly warns consumers to obtain credit through authorised banks and other legally authorised financial institutions.

A fintech planning balance-sheet lending should therefore obtain specific regulatory analysis before commencing operations.

10. P2P Lending: Can Individuals Lend to Other Individuals Through a Platform?

Classic P2P lending generally works as follows:

Investor A → Platform → Borrower B

Instead of the platform funding the loan, numerous investors finance borrowers.

This model raises several separate Turkish-law questions.

The platform may be:

• soliciting money from the public;
• holding investor funds;
• allocating those funds to borrowers;
• issuing contractual or financial rights;
• servicing repayments.

Those activities can interact with banking, capital-markets, payment and consumer-credit regulation.

Therefore, an ordinary website should not assume that it may freely collect money from thousands of persons and redistribute it as loans merely by describing the model as peer-to-peer lending.

11. Public Collection of Money Is Particularly Sensitive

Platforms collecting money from the public must exercise particular caution.

BDDK has publicly warned against unauthorised collection of cash or other value from citizens for investment or savings purposes and notes that unauthorised deposit-taking or operating like a bank can trigger serious criminal sanctions under the Banking Law.

Therefore, a P2P platform should not maintain an unregulated structure in which:

1. investors transfer money to the platform;
2. the platform pools that money;
3. the platform promises returns;
4. the money is distributed to borrowers.

The platform must identify the proper legal framework before accepting investor funds.

12. Debt-Based Crowdfunding Provides a Regulated Alternative

One of the most important developments for alternative lending in Türkiye is debt-based crowdfunding.

The SPK’s Crowdfunding Communiqué No. III-35/A.2 covers both:

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

The framework is based on Article 35/A of the Capital Markets Law and regulates crowdfunding platforms, investor participation and fundraising through electronic platforms.

This creates a regulated alternative-finance channel outside conventional bank lending.

But debt crowdfunding should not be confused with unrestricted consumer P2P lending.

13. What Is Debt-Based Crowdfunding?

Under the crowdfunding framework, debt-based crowdfunding involves raising funds from the public through a platform in return for a debt instrument issued by the entrepreneur or venture company.

The instrument represents an obligation to repay nominal value at maturity or according to the instalment structure disclosed in the information form.

The structure is therefore closer to regulated investment crowdfunding than an informal consumer-to-consumer loan marketplace.

It involves:

• investors;
• entrepreneurs or venture companies;
• regulated crowdfunding platforms;
• debt instruments;
• SPK disclosure rules.

This distinction is critical.

14. Debt Crowdfunding Is Now Operationally Significant

In December 2025, the SPK formally prepared and published standard information forms for debt-based crowdfunding by entrepreneurs and venture companies.

The SPK’s 2025 Annual Report states that these debt-based crowdfunding forms were published so listed platforms could conduct debt-based crowdfunding activities under the regulatory framework.

As of July 2026, debt-based crowdfunding should therefore be treated as a real component of Turkey’s alternative-finance framework rather than merely a theoretical legislative concept.

15. Crowdfunding Platforms Must Be Listed by the SPK

Crowdfunding platform activity is not open to any ordinary website operator.

The Capital Markets Law and Crowdfunding Communiqué require platforms to be included on the SPK’s list before conducting regulated crowdfunding activities.

The SPK currently publishes its official list of platforms authorised for crowdfunding activity.

A founder therefore cannot establish:

“CrowdLoanTurkey.com”

and begin issuing debt instruments to retail investors without completing the relevant SPK regulatory process.

16. 2026 Minimum Capital for Crowdfunding Platforms

For 2026, the minimum capital amount under Article 5(1) of the Crowdfunding Communiqué remains:

TRY 15 million.

The SPK’s 2026 revaluation decision expressly confirms this amount.

This is an important reminder that alternative-finance platforms are not treated like ordinary low-capital technology startups.

A regulated crowdfunding platform must satisfy capital and organisational requirements under capital-markets legislation.

17. 2026 Retail Investor Limits for Crowdfunding

Current 2026 crowdfunding rules also impose investment limits for non-qualified natural-person investors.

The maximum annual investment in equity- and debt-based crowdfunding is:

TRY 500,000.

Where the investor declares annual net income, the limit may instead be applied as the relevant income-based amount up to:

TRY 2 million.

For debt-based crowdfunding specifically, a non-qualified natural person may invest no more than:

TRY 200,000 in a single project.

These amounts are reflected in the SPK’s 2026 revaluation schedule.

Such investor protections distinguish regulated debt crowdfunding from an unrestricted online lending marketplace.

18. Debt Crowdfunding Is Not a Consumer Loan Marketplace

Founders should avoid interpreting the crowdfunding regime too broadly.

The SPK framework is designed around entrepreneurs, venture companies, projects and capital-market instruments.

It is not simply a licence for allowing any consumer to borrow money from anonymous retail investors for:

• holiday expenses;
• personal consumption;
• credit card repayment;
• ordinary household needs.

A general consumer P2P lending model therefore requires separate legal analysis.

The existence of debt crowdfunding does not mean every peer-to-peer loan platform automatically falls within it.

19. Debt Crowdfunding vs Financing Company Lending

These models should also be distinguished.

Financing Company

The financing company itself is the regulated creditor and finances the purchase of goods or services under Law No. 6361.

Debt Crowdfunding

Investors provide funding through an SPK-regulated platform in return for debt instruments issued under the crowdfunding framework.

The legal creditor/investor architecture is therefore different.

A founder should choose the model according to:

• borrower type;
• source of capital;
• funding purpose;
• investor structure.

20. Alternative Lending Through Payment Institutions

Payment institutions frequently want to enter lending because they already control strong customer and merchant distribution channels.

However, Law No. 6493 draws a clear boundary.

Payment institutions cannot grant credit.

Electronic money institutions are subject to the same prohibition.

The CBRT’s regulatory framework therefore permits payment companies to provide authorised payment services but does not turn them into lenders.

A payment company can nevertheless participate in an alternative lending ecosystem through services such as:

• repayment collection;
• account services;
• merchant settlement;
• payment execution.

The credit itself should remain with the authorised lender.

21. A Payment Licence Is Not a Marketplace Lending Licence

This distinction deserves particular emphasis.

A payment institution might provide:

• customer payment accounts;
• virtual IBANs;
• merchant acquiring;
• transfers.

That does not entitle it to use its balance sheet to lend customers money.

Nor does an EMI licence permit an electronic money institution to finance borrowers from customer e-money balances.

Alternative lending platforms should therefore avoid using payment or e-money licences as regulatory wrappers for lending activity.

22. Embedded Lending Through Payment Platforms

A legally cleaner structure may involve:

Payment Fintech A → customer interface and payment infrastructure

Financing Company B → loan

or:

Payment Fintech A → payment infrastructure

Bank B → loan

The customer may experience the entire credit journey inside the fintech application.

But the regulated lender should remain identifiable and substantively responsible for:

• underwriting;
• funding;
• credit contract;
• receivable ownership.

This structure allows payment businesses to monetise their distribution power without becoming lenders.

23. Merchant Cash Advance and Revenue-Based Financing

Merchant cash advance and revenue-based financing are increasingly popular internationally.

A typical model may provide:

TRY 500,000 today

in return for repayment from:

10% of future merchant sales.

Commercially, the financier may argue that this is not a loan because repayment fluctuates according to revenue.

However, Turkish regulatory classification should examine economic substance.

Questions include:

• Is there an obligation to repay principal?
• Is additional economic return required?
• Who bears the risk if future sales decline?
• Is the financier purchasing genuine receivables or advancing money?

Changing the repayment formula does not automatically remove the activity from financial regulation.

24. Purchasing Existing Receivables May Trigger Factoring Analysis

Alternative lending platforms sometimes use receivable financing instead of conventional loans.

Where the business purchases or finances existing commercial receivables, factoring regulation may become relevant.

Factoring companies are regulated non-bank financial institutions under Law No. 6361 and fall within BDDK’s supervision.

Therefore, a startup should not assume that calling a transaction:

• invoice finance;
• receivable advance;
• cash-flow finance

keeps it outside financial regulation.

The legal nature of the receivable transaction should be reviewed carefully.

25. Factoring Is Not the Same as Lending

Although both can provide liquidity, factoring and lending are legally distinct.

In a conventional loan:

borrower receives money → borrower owes repayment.

In a factoring structure:

a receivable is transferred or financed under the applicable factoring framework.

A digital platform should therefore determine whether it is actually:

• purchasing receivables;
• financing receivables;
• merely using receivables as security for a loan.

The regulatory category depends on substance.

26. Savings Financing Is Also a Separate Regime

Türkiye also has regulated tasarruf finansman, or savings-financing companies.

These companies form a distinct category under BDDK supervision. BDDK’s current organisation lists savings-financing companies separately from banks and ordinary financing companies, and new operating permissions continued to be published in 2026.

This regime should not be confused with:

• P2P lending;
• marketplace lending;
• BNPL;
• ordinary consumer lending.

A fintech cannot simply adopt a savings-pool model without considering the special regulatory framework.

27. Consumer vs Commercial Borrowers

Alternative lending regulation also depends heavily on the borrower.

A loan provided to a consumer for personal purposes can trigger Law No. 6502 and the Consumer Credit Agreements Regulation.

The Ministry of Trade defines consumer credit as financing provided to a consumer through deferred payment, loans or similar financing in return for interest, fees or similar benefits.

Commercial lending to:

• companies;
• merchants;
• entrepreneurs

may instead fall outside certain consumer protections, but financial licensing questions remain.

Therefore:

“B2B” may change consumer law, but it does not automatically eliminate financial regulation.

28. Digital Consumer Credit Is Legally Possible

Alternative lending does not require paper-based branch processes.

Turkish consumer credit agreements can be concluded:

• in writing;
• at distance.

The Ministry of Trade confirms that consumer credit agreements can be established remotely, provided applicable legal requirements are satisfied.

This enables genuine digital lending.

The platform can therefore provide:

• remote applications;
• electronic disclosures;
• digital credit agreements;
• automated repayments.

Innovation should occur within the regulated creditor structure rather than by avoiding it.

29. Consumer Credit Requires Clear Disclosure

Where alternative lending constitutes consumer credit, customers must be able to understand the financing.

Important matters include:

• identity of the creditor;
• credit amount;
• duration;
• interest;
• fees;
• repayment schedule.

The Ministry of Trade requires consumer credit agreements to be clear, understandable and readable and to be supplied to the consumer on paper or a permanent data storage medium.

A lending app should therefore not hide the actual loan terms behind an attractive “Get Cash” button.

30. Alternative Lenders Must Be Clearly Identified

One of the most important customer-protection principles is creditor transparency.

Where a fintech merely introduces the customer to Bank A, it should not imply:

“The platform is lending you the money.”

Where Financing Company B is the creditor, the financing company should be identified appropriately.

This is particularly important for embedded and white-label lending because the customer-facing brand may not be the actual financial institution.

The marketing architecture should match the contractual architecture.

31. AML/KYC Requirements

Alternative lending can create significant AML risks.

Potential risks include:

• fake borrowers;
• identity theft;
• use of loans to move illicit funds;
• shell companies;
• fraudulent merchant financing;
• misuse of investor money.

MASAK identifies:

• banks;
• financing companies;
• factoring companies;
• financial leasing companies;
• payment institutions;
• electronic money institutions

among the categories subject to AML/CFT obligations, with the specific compliance-programme structure depending on institution type.

The formal compliance programme includes elements such as:

• policies and procedures;
• risk management;
• monitoring and control;
• compliance function;
• training;
• internal audit.

Alternative lending should therefore not be designed only around credit scoring.

Financial crime controls are equally important.

32. Credit Risk and AML Risk Are Different

A customer can have an excellent credit score and still present AML risk.

For example:

A business may:

• have sufficient revenue to repay a loan;
• but operate through unusual third-party transfers;
• have opaque beneficial ownership;
• transact with high-risk countries.

Credit underwriting asks:

“Will the borrower repay?”

AML asks:

“Is the source and purpose of funds legitimate?”

Alternative lending platforms need systems capable of answering both questions.

33. Automated Credit Scoring

Alternative lending platforms frequently depend on automated data.

Possible data sources include:

• bank transactions;
• payment account activity;
• merchant turnover;
• invoices;
• e-commerce sales;
• repayment history.

This can reduce underwriting time substantially.

However, a platform should still establish:

• who makes the final credit decision;
• whether data are accurate;
• whether data processing is lawful;
• how fraud is detected.

A credit algorithm does not replace the regulated creditor.

34. Open Banking Can Support Alternative Lending

Turkish open banking allows authorised providers to offer Account Information Services and Payment Initiation Services.

Payment institutions’ exact Article 12 authorisations are publicly identified by the CBRT.

With the customer’s lawful participation, open banking data can potentially improve:

• cash-flow assessment;
• affordability analysis;
• SME underwriting.

However, an Account Information Service licence does not itself create lending authority.

A fintech can analyse accounts.

A properly authorised lender should provide the credit.

35. Payment Data and Lending Data Must Be Distinguished

A payment company may possess valuable information about customers.

However, use of data obtained for payment services for:

• credit scoring;
• loan marketing;
• sharing with lenders

requires separate legal analysis.

The fact that data are technically available does not mean they can automatically be reused for every commercial purpose.

Alternative lending platforms should therefore map both:

money flows

and

data flows.

36. Investor Money Must Be Separated From Platform Money

Where an alternative lending model involves investors rather than a bank or financing company, investor funds should not simply be transferred into the platform’s ordinary operating bank account.

Debt crowdfunding provides an example of a regulated architecture where funds are handled through the prescribed crowdfunding and custody structure rather than becoming unrestricted platform working capital.

This principle is commercially important even beyond crowdfunding:

A platform should not finance payroll and marketing expenses with money entrusted to it for financing borrowers.

37. Platform Insolvency Risk

P2P lending creates a serious question:

What happens if the platform fails?

A properly structured model should determine:

• who owns borrower receivables;
• who services loans;
• where investor money is held;
• whether another servicer can take over.

If the platform itself is simultaneously:

• lender;
• custodian;
• servicer;
• technology provider,

platform insolvency can disrupt the entire financing chain.

This is one reason regulated financial structures separate functions more carefully.

38. Foreign Alternative Lending Platforms Entering Turkey

A foreign P2P or marketplace lender should not assume that its overseas licence automatically works in Türkiye.

A UK lending authorisation, EU licence or US lending registration does not create a general Turkish passport.

Possible Turkish market-entry structures may include:

Technology Partnership

Foreign fintech supplies software while a Turkish authorised lender provides credit.

Bank Partnership

A Turkish bank funds borrowers.

Financing Company Partnership

A Turkish financing company provides qualifying finance.

Crowdfunding Platform

Where the activity genuinely falls within the SPK debt-crowdfunding regime, the business may consider the regulated crowdfunding architecture.

The correct route depends on:

• customer type;
• financing purpose;
• source of money;
• whether investors participate.

39. Foreign Platforms Should Not Collect Turkish Investor Money Without Analysis

A particularly sensitive structure occurs where a foreign online platform invites Turkish residents to invest in loans.

This can implicate:

• Turkish capital-markets rules;
• public offering/fundraising rules;
• crowdfunding;
• banking/fund-collection restrictions.

The platform should therefore obtain Turkish legal analysis before conducting local-language marketing or directly soliciting Turkish investors.

Cross-border digital delivery does not necessarily place the activity outside Turkish regulatory jurisdiction.

40. Crypto-Based Lending Is Not an Easy Regulatory Shortcut

Some alternative lenders attempt to use:

• stablecoins;
• crypto collateral;
• blockchain lending.

This does not automatically remove Turkish regulation.

Türkiye now operates a dedicated CMB regulatory regime for crypto asset service providers, while payment regulation separately restricts the use of crypto assets in payments.

Therefore, a model involving:

TRY → crypto → borrower → repayment

can potentially interact with more regulatory regimes, not fewer.

Alternative lending founders should avoid assuming that blockchain technology removes financial licensing questions.

41. Revenue-Based Financing Requires Case-by-Case Analysis

Revenue-based finance is attractive because repayment varies with business turnover.

For example:

Investor provides TRY 1 million.

Business pays 5% of monthly revenue until TRY 1.4 million has been paid.

The transaction may commercially differ from a fixed instalment loan.

However, Turkish legal analysis should still examine:

• repayment obligation;
• investment risk;
• financing return;
• securities-law implications;
• lending regulation.

A variable return does not automatically make an otherwise regulated financing activity unregulated.

42. Private Credit Funds and Institutional Lending Are Separate Topics

Alternative lending can also involve professional investment funds and institutional investors.

These structures can fall within separate capital-markets and fund-management rules.

They should not be confused with a retail P2P lending platform.

For fintech founders, the relevant distinction is:

platform matching ordinary consumers and retail investors

versus

regulated investment funds financing companies.

The latter may involve an entirely different regulatory architecture.

43. Advertising Alternative Loans

Alternative lenders frequently advertise:

• “instant credit”;
• “no bank required”;
• “loan in five minutes”;
• “credit for everyone.”

Marketing should not create false impressions concerning:

• licence status;
• approval certainty;
• total cost;
• creditor identity.

BDDK has previously warned the public about unlicensed online advertisements using claims such as instant, unconditional or guarantor-free loans and has emphasised that credit should be obtained from authorised institutions.

Marketing is therefore part of regulatory compliance.

44. An Ordinary Company Should Not Call Itself a Bank

Alternative lending branding should also avoid bank-like representations.

BDDK has taken enforcement action where unauthorised entities used terminology or documentation creating the impression that they conducted regulated banking or finance activity.

A platform should accurately describe itself as:

• technology platform;
• intermediary;
• regulated finance company;
• crowdfunding platform,

according to its real status.

Branding should follow authorisation.

45. Consumer Complaint Risk

Digital lending can create substantial complaint volumes involving:

• unauthorised applications;
• interest calculations;
• early repayment;
• credit reporting;
• repayment collection;
• identity theft.

Consumer-facing alternative lenders should therefore build complaint handling into product architecture.

Where consumer credit law applies, mandatory consumer rights cannot be excluded merely because the agreement is executed through an app.

46. Alternative Lending and Cybersecurity

Digital credit platforms hold highly valuable information.

Possible data include:

• identity records;
• bank transactions;
• income;
• business revenue;
• credit decisions;
• repayment history.

Cybersecurity weaknesses can therefore lead to:

• identity theft;
• fraudulent lending;
• account takeover;
• unlawful disclosure of financial information.

Alternative lending platforms should implement controls appropriate to the regulatory status of the entities involved.

Where banks, payment institutions or other regulated financial companies participate, sector-specific information security rules may also apply.

47. Alternative Lending M&A Due Diligence

Investors acquiring an alternative lending startup should conduct regulatory due diligence before relying on technology or loan-volume metrics.

The investigation should answer:

Who Funds the Loans?

Bank, financing company, investors or the startup itself?

Who Is the Creditor?

Review contracts and accounting.

Does the Startup Collect Investor Funds?

If yes, analyse capital-markets and banking implications.

Is the Business P2P?

Determine whether a specific authorised regulatory route exists.

Is Debt Crowdfunding Used?

Verify SPK platform status and campaign structure.

Are Receivables Purchased?

Consider factoring regulation.

Is a Payment Institution Involved?

Ensure it is not extending prohibited credit.

Are Consumers Borrowers?

Apply consumer credit law.

Is AML Operational?

Review borrower and investor onboarding.

A company can appear to be a simple SaaS platform while economically operating as an unlicensed financial institution.

48. Common Alternative Lending Compliance Mistakes

Mistake 1: “There Is No P2P Law, So P2P Lending Is Free”

Incorrect.

The activity must be assessed under banking, financing, crowdfunding, payment and other relevant financial legislation.

Mistake 2: “We Only Match Investors and Borrowers”

That may still create regulatory issues where the platform solicits public funds, handles investor money or facilitates financial instruments.

Mistake 3: “Our Payment Institution Can Fund the Loans”

Payment and electronic money institutions are not general lending institutions. Their CBRT licences cover specified payment/e-money services.

Mistake 4: “Debt Crowdfunding Is the Same as Consumer P2P Lending”

Incorrect.

Debt crowdfunding is a specific SPK-regulated capital-markets structure involving debt instruments, entrepreneurs/venture companies and regulated platforms.

Mistake 5: “Anyone Can Launch a Crowdfunding Website”

No.

Crowdfunding platforms must enter the SPK regulatory framework and be included on the official platform list.

Mistake 6: “Invoice Financing Is Always an Ordinary Loan”

The model may require factoring analysis depending on how receivables are transferred or financed.

Mistake 7: “Collecting Investor Money in Our Company Account Is Fine”

Pooling public/investor money can raise serious banking and capital-markets concerns.

Mistake 8: “A Foreign Lending Licence Automatically Covers Turkey”

There is no general passport allowing foreign lenders to ignore the Turkish financial regulatory perimeter.

Practical Alternative Lending Platform Compliance Checklist

Before launching an alternative lending platform in Türkiye, founders should answer the following questions.

What Is the Business Model?

P2P, marketplace lending, balance-sheet lending, debt crowdfunding or merchant finance?

Who Funds the Credit?

The platform, a bank, finance company or investors?

Who Is the Legal Creditor?

This should be evident from contracts.

Does the Platform Hold Investor Money?

If yes, analyse fund-collection and capital-markets regulation carefully.

Is a Bank Required?

Determine whether banking activities are involved.

Is a Financing Company Required?

Analyse purchase-financing functions under Law No. 6361.

Does the Model Involve Crowdfunding?

Review SPK Communiqué III-35/A.2.

Is the Platform on the SPK List?

Crowdfunding requires regulated platform status.

Does the Platform Buy Receivables?

Review factoring implications.

Is a Payment Institution Involved?

Keep lending separate from regulated payment services.

Are Consumers Borrowing?

Apply consumer credit protections.

Is the Customer Journey Digital?

Ensure distance contracts and disclosures are valid.

Is AML/KYC Properly Allocated?

Borrower, investor and beneficial-owner risks should be addressed.

Does the Platform Handle Personal Financial Data?

Review KVKK and sector requirements.

Does Marketing Identify the Real Creditor?

Avoid misleading “instant loan” claims by an unlicensed platform.

What Happens if the Platform Fails?

Plan loan servicing, data portability and investor protection.

Frequently Asked Questions About Alternative Lending Platforms in Turkey

Is P2P lending legal in Turkey?

Türkiye does not currently provide a general standalone P2P lending licence comparable to some foreign jurisdictions. A P2P model must be assessed under existing banking, financing, crowdfunding, capital-markets and payment legislation.

Can an ordinary fintech company lend money to consumers?

A fintech planning professional, repeated consumer lending should not assume that ordinary corporate registration is sufficient. Banks and regulated non-bank finance companies operate under dedicated BDDK regimes.

Can a fintech partner with a bank?

Yes. A platform can potentially provide technology, customer acquisition and digital interfaces while the bank remains the regulated lender.

Can a fintech partner with a financing company?

Yes. Financing companies are authorised non-bank financial institutions, and BDDK describes their core function as financing purchases by paying sellers on behalf of purchasers.

Can a payment institution lend money?

A payment licence concerns payment services rather than general lending. Payment and electronic money companies should keep their authorised payment functions separate from the credit function.

Does Turkey allow debt-based crowdfunding?

Yes. The SPK Crowdfunding Communiqué No. III-35/A.2 recognises debt-based crowdfunding, and the SPK has published dedicated debt-crowdfunding information forms.

Is debt crowdfunding the same as a loan marketplace?

No. Debt crowdfunding is a specific capital-markets mechanism based on debt instruments issued through regulated crowdfunding platforms.

What is the minimum capital for a crowdfunding platform in 2026?

The applicable minimum under Article 5(1) of the Crowdfunding Communiqué is TRY 15 million in 2026.

How much can a non-qualified individual invest in crowdfunding in 2026?

The general annual limit is TRY 500,000. Where annual net income is declared, the relevant maximum may rise to TRY 2 million under the current framework.

What is the per-project limit for a non-qualified investor in debt crowdfunding?

For 2026, the maximum investment by a non-qualified natural person in a single debt-crowdfunding project is TRY 200,000.

Can an online platform collect money from investors and lend it to borrowers?

Such a model can raise serious banking and capital-markets issues. Public collection and pooling of funds should not occur without identifying and satisfying the applicable legal regime.

Can merchant cash advance operate in Turkey?

The answer depends on the exact economic structure. Where the platform advances funds and requires repayment from future revenue, lending or other financial regulation may become relevant. Genuine receivable-financing structures may additionally require factoring analysis.

Can a foreign P2P platform serve Turkish users?

A foreign licence does not automatically create Turkish authorisation. The model should be analysed under Turkish lending, capital-markets, payment and data-protection rules.

Are financing companies subject to MASAK?

Yes. MASAK lists financing, factoring and financial leasing companies among obliged financial institutions.

Are alternative lending platforms subject to consumer credit law?

Where financing is provided to a consumer and meets the statutory consumer-credit definition, Law No. 6502 and the Consumer Credit Agreements Regulation can apply.

Conclusion: How Should an Alternative Lending Platform Be Structured in Turkey?

The regulation of alternative lending platforms in Turkey begins with a simple but fundamental principle:

Digital technology does not change who is legally lending the money.

An alternative lending application can modernise:

• onboarding;
• underwriting;
• comparison;
• customer acquisition;
• repayments.

But the legal financing function remains subject to Turkish financial regulation.

For many fintech startups, the lowest-risk model will therefore be:

technology platform + authorised lender.

The platform can develop the digital customer journey.

A bank or financing company can remain the legal creditor.

This structure allows the fintech to innovate without attempting to transform ordinary corporate registration into a lending licence.

Financing companies are particularly relevant to purchase finance.

BDDK defines their regulated model around financing purchases of goods or services through direct payment to the seller on behalf of the purchaser, followed by repayment from the borrower.

That model can support:

• embedded lending;
• e-commerce finance;
• checkout finance.

Alternative lending nevertheless extends beyond regulated lenders.

Türkiye now also has a meaningful debt-based crowdfunding framework.

The SPK Crowdfunding Communiqué expressly recognises borrowing-based crowdfunding, and dedicated debt crowdfunding disclosure forms were finalised in December 2025.

This creates a regulated route through which entrepreneurs and venture companies can raise funds from investors in return for debt instruments.

The framework includes substantial investor protection.

For 2026, a non-qualified natural person can generally invest a maximum of TRY 500,000 annually through equity- and debt-based crowdfunding, with a higher limit of up to TRY 2 million where annual net income is declared under the applicable formula. In debt crowdfunding, the maximum investment in one project is TRY 200,000.

The platform itself is also regulated.

The applicable minimum platform capital is TRY 15 million for 2026, and crowdfunding activity must take place through platforms included in the SPK framework.

Debt crowdfunding should nevertheless not be treated as a universal P2P lending licence.

It is a specific capital-markets structure.

A consumer-loan marketplace that allows ordinary individuals to lend money to other consumers raises separate questions.

The same caution applies to merchant financing.

A product described as:

merchant cash advance

or

revenue-based financing

may still be economically similar to credit where the financier provides money today and expects a larger amount to be repaid later.

Where the transaction instead concerns the acquisition or financing of existing commercial receivables, factoring rules may become relevant.

The legal analysis therefore requires looking beyond marketing terminology.

The correct questions are:

What asset is transferred?

Who funds the transaction?

Who carries default risk?

Who owns the receivable?

Payment institutions also have an important role—but not as general lenders.

The CBRT’s framework separately licenses payment and electronic money institutions for specific payment services and electronic money issuance.

These institutions can provide powerful infrastructure around alternative lending:

• account services;
• payment execution;
• repayment collection;
• merchant payments.

But the lending function should be separated from the payment licence.

A strong alternative lending ecosystem can therefore involve three layers:

Fintech Platform → technology and distribution

Authorised Lender → financing and credit risk

Payment Service Provider → movement and collection of money.

In a debt-crowdfunding model, a fourth structure appears:

SPK-regulated Platform → investors → debt instrument → entrepreneur/venture company.

Each architecture has different regulators, contractual relationships and risk allocation.

Fund collection deserves special attention.

BDDK has explicitly warned that unauthorised collection of funds from the public for investment or savings can violate Turkish law and, in certain circumstances, unauthorised banking or deposit-taking may result in criminal sanctions.

A P2P startup should therefore never begin by opening a company bank account and asking thousands of investors to transfer money into it.

The legal structure for holding funds should exist before the first investor payment is accepted.

The same is true for foreign companies.

A foreign marketplace lender should not treat the internet as a regulatory border.

Offering Turkish-language investment or lending services, soliciting Turkish investors or providing credit to Turkish customers can require local analysis even where the platform’s servers and parent company are abroad.

Consumer law adds another important layer.

Where a regulated lender finances a consumer, the Consumer Protection Law and Consumer Credit Agreements Regulation can require clear agreements, pre-contract information and other mandatory protections.

Digital lending therefore means:

digital contract, not no contract.

MASAK obligations also remain central.

Banks, financing companies, factoring companies, payment institutions and electronic money institutions form part of the Turkish AML framework, with the applicable compliance programme including risk management, monitoring, compliance functions, training and internal audit.

Alternative lending platforms should therefore combine:

credit underwriting + fraud detection + AML monitoring.

These are related but separate controls.

A borrower who can repay the loan can still be involved in suspicious financial activity.

Finally, investors should treat regulatory classification as a central element of M&A due diligence.

The most useful four questions are:

Who supplies the money?

Who legally owns the receivable?

Who takes the default loss?

Under whose licence is that activity conducted?

Where the answers do not match the company’s marketing story, further investigation is needed.

The recommended legal sequence for launching an alternative lending platform in Türkiye is therefore:

define the funding model → identify lender/investors → determine borrower type → analyse BDDK/SPK perimeter → determine whether crowdfunding, financing or factoring rules apply → separate payment functions → design fund custody → prepare consumer documentation → implement AML/KYC → structure data processing → launch only after regulatory classification is complete.

The central principle can be summarised as follows:

Alternative lending is legal innovation in the method of financing—not an exemption from Turkish financial regulation.

A platform can make lending:

• faster;
• more data-driven;
• more accessible;
• more automated.

But the regulatory foundations must remain clear.

For fintech founders and investors, choosing the correct architecture at the beginning is therefore one of the most important factors determining whether an alternative lending platform can scale legally and sustainably in Türkiye.

Legal Disclaimer: This publication provides general information concerning alternative lending, marketplace lending, P2P lending, financing companies, debt-based crowdfunding, merchant finance and related fintech regulation in Türkiye as of July 2026. It does not constitute legal, financial, tax or regulatory advice. The classification of any lending platform depends on the source of funds, creditor identity, borrower type, investor structure, repayment model, receivables, payment flow and contractual architecture. Each alternative lending model should therefore be individually reviewed under Banking Law No. 5411, Law No. 6361, Capital Markets Law No. 6362, Law No. 6493, consumer legislation, MASAK requirements and other applicable regulations before launch.