Introduction: Can Fintech Payment Companies Provide Loans in Turkey?

The relationship between fintech and lending is one of the most misunderstood areas of Turkish financial regulation.

A fintech application may already allow its customers to:

• maintain a payment account;
• hold electronic money;
• receive a virtual IBAN;
• transfer funds;
• make card payments;
• use a digital wallet;
• receive merchant payments.

From a commercial perspective, adding a lending product can appear to be the natural next step.

A payment institution may want to give a customer a temporary negative balance.

An electronic money institution may want to provide an advance against expected salary or merchant revenue.

A digital wallet may want to introduce a “Pay Later” button.

A payment company serving merchants may want to advance tomorrow’s settlement today.

However, Turkish law draws a very clear boundary between payment services and credit granting.

Under Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions, payment institutions cannot engage in credit-granting activities. Electronic money institutions are subject to the same prohibition. The Central Bank of the Republic of Türkiye (“CBRT” or “TCMB”) is authorised to determine how activities connected with payment services should be classified for purposes of this prohibition.

The current Payment Services Regulation makes the rule even more explicit:

payment and electronic money institutions cannot grant credit, cannot market themselves in a manner creating the impression that they provide credit, and cannot instalment amounts whose payment they intermediate.

The Regulation contains only a narrowly defined exception relating to specified telecommunications/electronic communications billing transactions.

Therefore, the starting principle for fintech lending in Turkey is straightforward:

A payment institution licence or electronic money institution licence is not a lending licence.

This does not mean payment and e-money companies cannot participate in lending ecosystems.

They can potentially provide:

• payment infrastructure;
• repayment collection;
• merchant settlement;
• customer interfaces;
• open banking data;
• technical credit-scoring tools;
• regulated payment services connected with a loan.

However, where actual credit is being extended, the lender must generally be an institution legally authorised to perform the relevant financing activity, such as a bank or financing company, depending on the structure.

This guide explains how that boundary operates in Türkiye as of July 2026.

1. The Fundamental Rule: Payment Institutions Cannot Grant Credit

Article 14(4) of Law No. 6493 expressly provides that a payment institution cannot engage in credit-granting activity.

The same provision authorises the CBRT to determine through secondary regulation whether activities connected with payment services amount to credit granting.

This prohibition should be understood broadly.

A payment institution should not assume that only a traditional cash loan is prohibited.

Regulatory analysis should examine whether the institution is economically:

• advancing its own money to a customer;
• financing a customer’s purchase;
• permitting repayment at a later date;
• carrying customer credit risk;
• creating a receivable against the customer.

The commercial terminology used for the product does not determine the legal result.

Calling the product:

• “advance”;
• “early balance”;
• “wallet flexibility”;
• “instant spending limit”;
• “Pay Later”

does not necessarily prevent it from being characterised as credit.

2. Electronic Money Institutions Are Subject to the Same Prohibition

Law No. 6493 Article 20(4) independently provides that an electronic money institution cannot engage in credit-granting activity.

The current version of the law also authorises the CBRT to determine whether activities conducted by an EMI in connection with payment services fall within credit granting.

This distinction is important because electronic money institutions may look commercially similar to banks.

An EMI can potentially offer customers:

• stored electronic value;
• payment accounts;
• payment cards;
• virtual IBANs;
• transfers;
• merchant payments.

But an electronic money institution is not a deposit bank and does not acquire banking lending powers merely because it manages customer balances.

The CBRT’s current register separately identifies institutions authorised to issue electronic money under Article 18(2) and lists their individual payment-service permissions.

None of that converts the EMI licence into authority to extend credit.

3. The Current Regulation Makes the Lending Ban Extremely Clear

Article 16 of the current Payment Services Regulation is titled “Kredi kullandırma yasağı” — Prohibition on Granting Credit.

The first paragraph states that an institution:

• cannot grant credit;
• cannot conduct advertising or marketing that creates the impression that it grants credit;
• cannot instalment amounts whose payment it intermediates.

This is broader than merely prohibiting a classic loan contract.

The provision also regulates the customer experience and commercial presentation.

Accordingly, a payment institution should not advertise:

“Get TRY 20,000 instant credit from your wallet”

where the institution itself is not legally entitled to grant that credit.

Even creating the impression that the payment institution itself is the lender can create regulatory problems.

4. Payment Companies Cannot Simply Instalment a Payment

The second particularly important part of Article 16(1) is the rule that amounts whose payment is intermediated by the institution cannot be instalmented.

Consider the following transaction:

Customer buys goods for TRY 12,000.

Payment Institution A processes the payment to Merchant B.

Payment Institution A tells the customer:

“We will pay the merchant now. You can repay us in four monthly instalments.”

That structure moves well beyond ordinary payment intermediation.

The institution has effectively financed the payment.

The fact that the original transaction began as a regulated payment service does not authorise the institution to transform the payment into a credit receivable.

5. Payment Processing and Credit Must Be Separated

This distinction can be expressed through a simple example.

Permitted Payment Role

Bank A grants the customer a TRY 50,000 consumer loan.

Payment Institution B transfers the loan proceeds or processes repayments within its authorised payment-service scope.

Problematic Lending Role

Payment Institution B itself advances TRY 50,000 from its own balance sheet to the customer and requires the customer to repay it later.

In the first structure:

Bank = lender

Payment institution = payment service provider

In the second:

Payment institution = lender

The second structure conflicts with the credit prohibition under Law No. 6493 and Article 16 of the Regulation.

6. Can a Payment Institution Offer an Overdraft?

A conventional overdraft is particularly difficult to reconcile with the statutory framework.

Suppose the customer has:

TRY 1,000 balance

but the payment institution allows:

TRY 3,000 spending.

The institution has economically advanced the additional TRY 2,000.

If the customer is required to reimburse that amount later, the arrangement strongly resembles lending.

The same issue can arise where an application displays:

Available balance: TRY 1,000

Spending power: TRY 5,000

If the extra TRY 4,000 is financed by the payment institution itself, the commercial label “spending power” does not eliminate the lending analysis.

A payment account should therefore not be transformed into a credit line by the payment institution.

7. Can an Electronic Money Wallet Have a Negative Balance?

The same principle applies to electronic money.

Electronic money is fundamentally value issued against funds received.

Law No. 6493 requires the electronic money issuer to issue electronic money corresponding to funds received, while separately prohibiting EMIs from lending.

Accordingly, a wallet balance should not ordinarily operate like:

Wallet balance: -TRY 5,000

where the negative balance represents credit extended by the EMI.

That would fundamentally change the economic nature of the product from prepaid/stored electronic value into borrowing.

8. Customer Funds Cannot Become a Lending Pool

Another important distinction concerns the source of money used in fintech lending.

Payment and electronic money institutions operate under detailed safeguarding rules for payment and electronic money funds.

For electronic money specifically, Law No. 6493 requires funds collected in exchange for electronic money to be placed into the prescribed banking structure, while electronic money itself must correspond to funds received.

A fintech cannot therefore reason:

“We hold large customer balances, so we can lend part of those balances to other customers.”

That would fundamentally conflict with the regulatory separation between:

• protected customer/payment funds;
• the institution’s own assets;
• lending activity.

Customer money held for payment or electronic money purposes is not equivalent to bank deposits available for a payment institution to transform into a loan book.

9. The TRY 40 Million and TRY 105 Million Requirements Do Not Create Lending Capacity

A common misunderstanding concerns regulatory capital.

From 30 June 2026, the minimum own-funds thresholds are:

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

These amounts are prudential requirements.

They are not lending limits.

A payment institution with TRY 100 million of own funds cannot say:

“Our minimum is only TRY 40 million, so we can lend the remaining TRY 60 million.”

The credit prohibition applies because of the institution’s regulated activity, not because it lacks capital.

The same principle applies to an EMI holding capital far above TRY 105 million.

More capital does not transform the EMI into a bank or financing company.

10. Can a Payment Institution Offer BNPL?

A payment institution cannot normally provide Buy Now Pay Later financing itself where the commercial model requires the institution to pay today and collect the debt from the customer later.

Article 16 is particularly relevant because it expressly prohibits both credit granting and instalmenting amounts whose payment is intermediated.

Therefore, the following structure is problematic:

Customer buys product → PI pays merchant → customer repays PI in four instalments.

The more appropriate architecture is:

Customer → regulated lender → merchant

with a payment institution potentially handling authorised payment functions around the financing.

The lender might be:

• a bank;
• a licensed financing company;

depending on the product.

11. Can an EMI Offer BNPL Through Its Wallet?

An EMI can potentially integrate a BNPL offer into its wallet.

But integration is different from lending.

For example:

EMI A operates the customer’s wallet.

Bank B provides the consumer credit.

The application displays:

“Pay in four instalments with Bank B.”

The bank approves and funds the financing.

The EMI processes payment or repayment functions within its licence.

This is fundamentally different from:

EMI A advances its own funds and collects repayment over four months.

The latter conflicts directly with the statutory lending prohibition.

12. Can Payment Companies Offer Merchant Cash Advances?

Merchant-financing models require equally careful analysis.

Suppose a payment company processes TRY 1 million of monthly merchant payments.

It offers:

“Receive TRY 300,000 today and repay automatically from 15% of future POS turnover.”

Commercially, the product may be described as:

• merchant advance;
• revenue-based financing;
• settlement advance.

However, the legal classification should follow economic substance.

Where the payment institution advances its own funds to the merchant and expects repayment from future revenues, the transaction can display the characteristics of credit.

Calling repayment a “percentage of future turnover” does not automatically eliminate the lending issue.

A payment institution considering this structure should separate:

payment settlement

from

merchant financing.

A bank or financing company may need to provide the financing component.

13. Early Settlement Is Different From Lending—But Structure Matters

Payment companies often settle merchant transactions according to agreed settlement cycles.

For example:

T+1 settlement

or

T+7 settlement.

Changing settlement timing is not necessarily the same thing as granting credit.

The key question is whether the institution is paying money that is already economically owed to the merchant from completed payment transactions or whether it is advancing independent financing against future transactions that do not yet exist.

This distinction should be documented carefully.

The further the product moves from:

settling an existing payment receivable

toward

advancing money against expected future income,

the stronger the lending concern becomes.

14. A Narrow Telecommunications Exception Exists

The current Payment Services Regulation contains one specific exception to the general credit prohibition.

For payment services within Article 4(1)(d), involving qualifying electronic communications transactions charged to the customer’s telecommunications bill, collection by the telecommunications provider until the bill’s due date is not treated as credit.

However, this exception is narrow.

The Regulation also provides that, in this structure, the payment institution cannot:

• pay the recipient before the relevant bill amount has been collected;
• guarantee that payment before collection.

This condition is critical.

The rule does not create a general “30-day free credit” exception for fintechs.

It concerns a specifically regulated telecommunications billing model.

15. The Telecommunications Exception Has Transaction Limits

The Regulation also imposes risk-management and monetary limits on this model.

The institution must assess the customer’s risk, including relevant past bill-payment behaviour, and set transaction and monthly limits.

Under the current text, the limits are:

• TRY 1,000 per transaction;
• TRY 2,750 total monthly spending across the customer’s relevant lines with that telecommunications operator.

The CBRT may increase these limits up to three times.

Accordingly, the provision should not be treated as a general legal foundation for fintech lending.

It is a carefully constrained payment-services exception.

16. Even the Telecommunications Exception Has Default Controls

If the telecommunications bill remains unpaid beyond the regulatory period, the institution must stop providing the service.

The current Regulation provides additional restrictions where the non-payment continues for a longer period.

The existence of these detailed protections reinforces the larger conclusion:

Where the CBRT intended to permit limited deferred collection without treating it as credit, it did so expressly and under strict conditions.

Fintech companies should therefore be cautious about inventing broader credit exceptions by analogy.

17. Payment Companies Cannot Market Themselves as Lenders

Article 16 does not merely prohibit credit.

It also prohibits institutions from conducting advertising or marketing activities that create the impression that they provide credit.

This affects:

• website wording;
• mobile app interfaces;
• push notifications;
• advertisements;
• social media;
• co-branded lending products.

Suppose the actual lender is Bank A but Payment Institution B advertises:

“Borrow instantly from B.”

That wording can create regulatory risk.

A more accurate approach would identify the actual creditor clearly.

18. Co-Branded Lending Products Must Identify the Lender

Payment companies can commercially participate in lending partnerships.

A wallet may display a loan marketplace.

A payment institution may integrate credit applications.

A fintech may perform payment collection for a finance company.

But customer communications should distinguish:

technology/payment provider

from

creditor.

The customer should understand:

• who grants the credit;
• who receives repayment;
• who determines interest and fees;
• which entity handles credit complaints.

The payment brand should not obscure the regulated lender.

19. Banks Provide a Natural Lending Partner

Banks are one of the clearest potential partners for fintech lending.

A fintech can integrate:

• loan applications;
• eligibility interfaces;
• repayment functionality;
• payment services.

The bank can remain responsible for:

• underwriting;
• credit approval;
• funding;
• credit agreement;
• loan receivable.

The fintech does not need to become the lender merely because the credit application occurs within its application.

This structure is particularly relevant to embedded finance.

20. Financing Companies Are Another Important Lending Route

Türkiye also has a regulated financing-company sector supervised by the BDDK.

The BDDK describes a financing agreement as one where a financing company finances the purchase of goods or services by making payment directly to the seller on behalf of the purchaser, with repayment subsequently made by the borrower to the financing company.

This structure is particularly suitable for:

• checkout financing;
• merchant finance;
• embedded purchase finance;
• certain BNPL products.

The BDDK’s current public list confirms an active regulated financing-company market in 2026.

Payment and electronic money institutions seeking to add credit can therefore consider partnerships with regulated financing companies rather than attempting to lend themselves.

21. A Legal Embedded Lending Architecture

A possible Turkish embedded lending model may look like:

Customer → Fintech Application → Financing Company → Merchant

while:

Payment Institution → executes authorised payment flows.

The fintech may provide:

• user interface;
• technology;
• merchant integration;
• scoring support.

The financing company provides:

• credit;
• funding;
• receivable;
• regulated lending decision.

The payment institution handles:

• payment execution;
• collection;
• account services,

within its Article 12 licence scope.

This creates a much clearer regulatory separation.

22. Technology Providers Can Support Credit Underwriting

A fintech technology company can potentially supply:

• credit scoring algorithms;
• income analysis;
• fraud detection;
• onboarding tools;
• bank-account analytics.

But providing technology for credit underwriting is different from legally becoming the lender.

The regulated creditor should retain the final responsibility required by its own financial-sector regime.

A software provider should therefore avoid contractual arrangements where:

• it funds the credit;
• it economically guarantees every default;
• the licensed lender has no substantive decision-making function.

The legal architecture should correspond to commercial reality.

23. Payment Data Can Be Used for Credit Scoring—But With Limits

Payment institutions possess valuable data.

They may know:

• account inflows;
• merchant turnover;
• spending patterns;
• payment history.

Such data can potentially support credit-risk analysis by an authorised lender.

However, two separate legal questions must be answered:

1. Is the use permitted under the financial-sector regulatory relationship?
2. Is personal data processing lawful under KVKK?

In July 2026, the Personal Data Protection Authority and TÖDEB published a dedicated Good Practices Guide for the payment and electronic money sector covering controller/processor roles, processing conditions, transfers and data security.

Payment data should therefore not automatically be treated as freely reusable lending data.

24. KYC Data Is Not Automatically Credit-Marketing Data

A payment institution may collect personal information because it is legally required to identify a customer.

That does not automatically mean the same information can be used without further analysis for:

• targeted loan advertising;
• behavioural profiling;
• credit scoring;
• sharing with third-party lenders.

The purposes and legal grounds for each processing operation should be mapped separately.

This becomes especially important where a payment application contains a lending marketplace involving several creditors.

25. MASAK Compliance Remains Relevant

Payment and electronic money institutions remain subject to Turkish AML/CFT requirements regardless of whether they participate in lending partnerships.

MASAK’s current framework requires electronic money institutions and most payment institutions to operate formal compliance programmes.

The programme includes:

• institutional policies and procedures;
• risk management;
• monitoring and control;
• compliance officer/unit;
• training;
• internal audit.

Financing companies are likewise within the relevant AML compliance framework.

A lending partnership therefore requires coordination among regulated institutions rather than assuming one participant’s KYC automatically eliminates the obligations of another.

26. Consumer Credit Rules Apply Where the Borrower Is a Consumer

Where the actual lender provides credit to a consumer, Law No. 6502 and the Consumer Credit Agreements Regulation become important.

The Ministry of Trade defines a consumer credit agreement as one where a creditor provides or promises credit to a consumer through deferred payment, a loan or similar financing in return for interest, fees or a similar benefit.

This definition is broader than traditional bank lending.

It can be relevant to:

• digital loans;
• checkout finance;
• embedded credit;
• BNPL-type structures.

The customer experience may occur in a fintech application, but mandatory consumer-credit rights remain relevant.

27. Consumer Credit Agreements Can Be Concluded Digitally

Consumer-credit regulation does not prevent digital lending.

The Ministry of Trade confirms that consumer credit agreements can be established:

• in writing;
• at distance,

provided the legally required conditions are met.

This means fintech lending can remain fully digital.

A customer does not necessarily need to visit a branch.

However, digital execution does not eliminate requirements concerning:

• disclosure;
• contractual content;
• withdrawal rights;
• repayment information.

28. Consumers Have a 14-Day Credit Withdrawal Right

The Ministry of Trade states that a consumer generally has 14 days to withdraw from a consumer credit agreement without giving a reason and without contractual penalty.

This right also applies to qualifying remotely concluded consumer credit.

Where a payment or e-money application integrates lending from a bank or financing company, the user journey should therefore support the lender’s consumer-law obligations.

The interface should not make exercising withdrawal rights practically impossible.

29. Acceleration of Consumer Credit Is Restricted

Turkish consumer law also restricts when an entire instalment debt can be accelerated.

According to the Ministry of Trade, the creditor’s acceleration right generally requires, among other conditions:

• the creditor to have performed its own obligations;
• the consumer to have failed to pay at least two consecutive instalments;
• at least 30 days’ warning before acceleration.

Automated fintech collection systems should therefore not be designed around foreign template rules that automatically accelerate the full balance after one missed payment.

30. Credit Servicing and Payment Collection Are Different From Lending

A payment institution can potentially collect loan repayments for a licensed creditor where the activity falls within its authorised payment-service scope.

For example:

Borrower owes Bank A TRY 5,000.

Payment Institution B enables repayment.

The payment institution is processing a payment.

It is not necessarily extending credit.

The distinction is:

credit creation versus credit servicing/payment execution.

Fintech companies should preserve this distinction contractually and operationally.

31. Payment Institutions Can Become Valuable Lending Distribution Channels

The credit prohibition does not make payment institutions commercially irrelevant to lending.

Quite the opposite.

Payment platforms can be powerful lending distribution channels because they already have:

• customer interfaces;
• digital onboarding technology;
• payment data;
• merchant networks.

A properly structured partnership can allow:

payment fintech = distribution and payment infrastructure

bank/finance company = lender

The business can therefore monetise embedded lending without violating the lending prohibition.

32. Merchant Lending Through Payment Platforms

Merchant lending is particularly attractive.

A payment platform already knows a merchant’s:

• transaction volume;
• settlement history;
• refund rates;
• chargebacks.

This information can help an authorised lender assess credit risk.

A compliant model may therefore involve:

1. payment institution supplies merchant-payment data in a legally permissible structure;
2. financing company or bank performs credit assessment;
3. regulated lender advances credit;
4. repayment is collected through authorised payment channels.

The payment institution should not itself become the creditor unless it has separately acquired a legally authorised lending status through an appropriate structure.

33. Can a Payment Company Guarantee a Loan?

Guarantees require careful analysis.

A payment company may commercially want to tell a lender:

“We guarantee repayment of all loans issued through our app.”

Depending on structure, that arrangement can materially change the institution’s risk profile and may raise questions concerning activities permitted under its regulatory framework.

At minimum, it should not be assumed that a payment institution can replicate the economic function of lending by formally placing the credit on another entity’s balance sheet while economically assuming the entire financing risk itself.

The legal structure must reflect genuine allocation of functions.

34. Can a Payment Institution Buy Loan Receivables?

A payment institution considering acquiring credit receivables should likewise conduct a separate regulatory analysis.

The payment institution’s permitted commercial activities are restricted by the Payment Services Regulation.

Its regulatory status is designed around payments—not building a loan or purchased-credit portfolio.

A business model involving acquisition, financing or collection of loan receivables may interact with:

• banking;
• financing-company;
• factoring;
• asset-management regulation,

depending on the exact transaction.

It should not be assumed to fall automatically within a payment licence.

35. Can an EMI Pay Interest on Customer Balances?

No.

This is another important distinction between EMIs and banks.

Law No. 6493 provides that an electronic money issuer cannot pay interest or provide a benefit linked to:

• how long electronic money is held;
• the amount of electronic money held.

This means an EMI cannot turn its wallet into a deposit-like savings and lending model.

Electronic money is designed for payments, not bank-style financial intermediation.

36. Lending Through a Separate Group Company

A fintech group might consider:

Payment Institution A

and

Financing Company B

within the same corporate group.

Such a structure may potentially separate payments from lending more effectively.

However, each regulated entity must still comply independently with:

• licensing;
• governance;
• capital;
• AML;
• data protection.

The existence of a common shareholder does not merge their regulatory permissions.

Payment Institution A cannot lend merely because sister company B has financing authority.

Likewise, data cannot automatically be transferred between group entities without analysing applicable legal grounds and sector rules.

37. White-Label Lending

A payment or electronic money company may also integrate a white-label credit product.

For example, the application may display:

“Instant Finance”

while Financing Company B is the actual lender.

This can potentially be structured lawfully provided customer communications clearly identify the creditor.

The payment fintech should not:

• describe itself as the lender;
• create misleading credit advertising;
• hide the identity of the regulated creditor.

Article 16’s prohibition on creating the impression that a payment/e-money institution grants credit is directly relevant.

38. Credit Advertising Must Match Regulatory Reality

Product design teams should review wording carefully.

Higher-risk expressions include:

“Our loan”

“We approved your credit”

“Borrow from your e-wallet”

where the payment/EMI entity is not the actual creditor.

Safer regulatory presentation should clearly identify:

• the lender;
• the payment provider;
• applicable terms.

Marketing should reflect the contractual and financial architecture.

39. Payment Institution vs Financing Company

The distinction can be summarised as follows.

Payment Institution

Primary regulated function:

• payment execution;
• payment accounts;
• transfers;
• acquiring;
• other authorised payment services.

Cannot grant credit.

Financing Company

Primary regulated function includes financing purchases of goods or services by paying the seller on behalf of the purchaser and receiving repayments from the borrower.

The two businesses can cooperate.

They should not be treated as interchangeable licences.

40. Payment Institution vs Bank

A payment institution can offer account and transfer functionality that looks increasingly bank-like.

But Turkish law still imposes a clear boundary.

The Payment Services Regulation provides that payment/e-money institutions cannot accept deposits or participation funds and cannot use documentation or advertising that creates the impression they are banks.

The credit prohibition creates another major distinction.

Banks can conduct lending within banking law.

Payment institutions cannot.

Giving customers IBANs, cards or wallets does not erase that distinction.

41. Foreign Fintech Lenders Entering Turkey

A foreign fintech may operate as a lender in:

• Europe;
• the United Kingdom;
• the United States;
• another jurisdiction.

That does not automatically allow it to provide credit to Turkish consumers merely because it also has a Turkish payment partner.

A Turkish payment institution cannot act as a regulatory wrapper allowing an unlicensed foreign company to conduct domestic lending through the payment institution’s licence.

Foreign lenders should separately analyse:

• banking regulation;
• financing-company regulation;
• consumer credit;
• cross-border structuring;
• Turkish tax and foreign exchange issues.

The payments layer and lending layer require separate regulatory treatment.

42. Lending Compliance Is Not Solved by Calling the Product “Advance”

Fintech marketing frequently uses alternative terminology.

Examples include:

• salary advance;
• merchant advance;
• cash advance;
• instant balance;
• spending advance.

Legal classification should focus on whether:

1. money or purchasing power is supplied today;
2. the customer has an obligation to repay later;
3. the provider carries repayment risk.

Where those elements are present, the product deserves serious credit-regulation analysis.

The label cannot override economic substance.

43. Can an Employer Salary Advance Be Different?

Not every advance in commercial life necessarily constitutes regulated financial lending.

For example, an employer advancing salary already expected to become due raises different legal issues from a fintech systematically financing unrelated customers for profit.

Similarly, a merchant deferring payment for its own goods can fall under different consumer rules from a standalone financial institution.

The precise commercial relationship therefore matters.

However, a payment institution should not rely on those broader private-law concepts to circumvent the express Article 16 credit prohibition.

Its own regulatory restrictions remain decisive.

44. Fintech Lending and Alternative Lending Platforms

A fintech may also act as a marketplace connecting borrowers and regulated lenders.

Such a platform should distinguish itself from the creditor.

Potential functions may include:

• application intake;
• document collection;
• lender comparison;
• scoring technology;
• loan servicing interfaces.

Whether additional financial regulation is triggered depends on the full structure.

The platform should obtain separate legal analysis if it begins:

• pooling investor money;
• funding loans itself;
• acquiring receivables;
• guaranteeing borrower obligations.

45. Regulatory Capital Does Not Replace Licence Scope

The 2026 capital increases have made payment and e-money institutions significantly better capitalised.

But licence scope remains more important than balance-sheet size.

A TRY 500 million-capital EMI still cannot lend merely because it has surplus equity.

A TRY 200 million-capital payment institution remains subject to Article 16.

Regulatory capital answers:

“How financially resilient must this institution be?”

It does not answer:

“Which financial services may this institution legally provide?”

These questions must remain separate.

46. Current Supervision Is Active

The CBRT continues to maintain detailed public registers showing active payment and electronic money institutions and their precise licence scopes.

The EMI register also currently identifies multiple institutions whose operating permissions have been cancelled, demonstrating that regulatory status is actively supervised and can change.

A fintech lending partnership should therefore verify the regulatory status of payment partners continuously rather than only at contract signing.

47. Fintech Lending Due Diligence Checklist

Investors evaluating a payment or e-money company offering lending-related features should ask:

Who Is the Legal Creditor?

The answer should be clear.

Who Funds the Loan?

Payment institution, EMI, bank or financing company?

Who Carries Credit Risk?

Economic substance matters.

Does the Payment Institution Have Negative-Balance Customers?

This may indicate disguised lending.

Are Merchant Payments Instalmented by the PI?

Article 16 expressly prohibits this.

Does Marketing Claim the PI Provides Credit?

This can itself be problematic.

Is a Regulated Lender Involved?

Verify BDDK status where relevant.

Are Customer Funds Being Used for Financing?

Safeguarded payment/e-money money should not become an informal loan pool.

Is Consumer Credit Law Followed?

Check digital contracting, disclosures and withdrawal.

Is Data Shared Lawfully?

Review KVKK and lender/fintech information flows.

48. Common Fintech Lending Mistakes in Turkey

Mistake 1: “A Payment Institution Is a Financial Company, So It Can Lend”

Incorrect.

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

Mistake 2: “Electronic Money Institutions Can Lend Because They Hold Customer Balances”

Incorrect.

EMIs are separately prohibited from granting credit.

Mistake 3: “We Call It an Advance, Not a Loan”

The legal analysis follows the economic substance.

Mistake 4: “We Can Instalment the Payment Because We Have Acquiring Permission”

Incorrect.

Article 16 expressly states that amounts whose payment is intermediated cannot be instalmented by the institution.

Mistake 5: “Our EMI Can Offer BNPL From Its Own Balance Sheet”

Not within the ordinary payment/e-money licence framework.

Mistake 6: “We Have TRY 105 Million Own Funds, So We Can Create a Loan Book”

The EMI own-funds requirement does not create lending authority.

Mistake 7: “A Bank Is in the Background, So We Can Advertise the Credit as Ours”

Article 16 also prohibits marketing that creates the impression that the payment/e-money institution grants credit.

Mistake 8: “All Deferred Payments Are Prohibited”

Too broad.

The Regulation itself contains a narrow telecommunications billing exception, and ordinary commercial/consumer instalment arrangements outside a payment institution require their own separate legal analysis.

Practical Fintech Lending Compliance Checklist for Turkey

Before a payment or electronic money company introduces a lending-related product, management should ask:

Is Money Being Advanced?

Who supplies it?

Does the Customer Repay Later?

To whom?

Does the Fintech Carry Credit Risk?

If yes, lending regulation becomes highly relevant.

Does the Product Create a Negative Balance?

Review whether this constitutes prohibited credit.

Is a Payment Being Instalmented?

Payment/e-money institutions cannot instalment amounts whose payment they intermediate.

Is the Product BNPL?

Identify the regulated lender separately.

Is the Product a Merchant Advance?

Determine whether it is merely accelerated settlement or independent financing.

Is the Product Marketed as Credit?

An institution cannot create the impression that it grants credit.

Is a Bank Involved?

Allocate lending and payment functions clearly.

Is a Financing Company Involved?

Confirm BDDK authorisation and creditor role.

Is Customer Credit Data Shared?

Review KVKK.

Is the Borrower a Consumer?

Apply consumer credit rules.

Is the Loan Agreement Digital?

Ensure mandatory information and documentation are provided.

Is AML Allocation Clear?

Determine responsibilities of payment provider and creditor.

Are Customer Funds Protected?

Do not use payment or electronic money funds as lending capital.

Frequently Asked Questions About Fintech Lending in Turkey

Can a payment institution provide a loan in Turkey?

No. Law No. 6493 expressly states that payment institutions cannot engage in credit-granting activity.

Can an electronic money institution provide credit?

No. Law No. 6493 separately prohibits electronic money institutions from granting credit.

Can a payment institution allow a customer’s account to go negative?

A structure in which the institution advances funds and requires later repayment can constitute credit and should be analysed against the express lending prohibition.

Can an EMI provide an overdraft on an e-money wallet?

A conventional negative-balance/overdraft arrangement financed by the EMI is difficult to reconcile with the statutory credit prohibition and the prepaid nature of electronic money.

Can a payment institution offer Buy Now Pay Later?

It cannot itself grant the underlying credit merely under its payment institution licence. It can potentially participate in payment processing while an authorised bank or financing company provides the financing.

Can an EMI offer BNPL?

It may integrate a product supplied by a separate regulated creditor, but the EMI cannot itself become the lender under its e-money licence.

Can a payment institution split a merchant payment into instalments for the customer?

Article 16 expressly states that amounts whose payment is intermediated by the institution cannot be instalmented.

Is there any exception?

The Regulation contains a narrow exception for specified electronic communications payments charged to a telecommunications bill and collected by its due date. The institution cannot pay the recipient or guarantee payment before the bill amount is collected.

What are the current limits for that telecommunications exception?

The current Regulation provides a TRY 1,000 per-transaction limit and TRY 2,750 monthly total limit in the specified structure, subject to the CBRT’s power to increase them by up to three times.

Can a payment institution advertise credit offered by a bank?

It may participate in a properly structured partnership, but the marketing should clearly identify the actual lender. Article 16 prohibits creating the impression that the payment/e-money institution itself grants credit.

Can payment institutions collect loan repayments?

Potentially yes, where repayment processing falls within the payment institution’s authorised payment-service scope. Payment servicing and granting the underlying loan are different functions.

Can a financing company provide fintech credit?

Yes. BDDK states that financing companies can finance goods or services by paying the seller directly on behalf of the purchaser, with repayment made by the borrower to the financing company.

Can a fintech partner with a bank for lending?

Yes. A properly structured model can leave underwriting, funding and the credit relationship with the bank while the fintech provides technology and authorised payment services.

Can a payment company use its regulatory own funds for loans?

The fact that it holds capital above its minimum requirement does not remove the statutory lending prohibition.

What are the 2026 minimum own-funds requirements?

From 30 June 2026, the minimum is generally TRY 40 million for ordinary payment institutions and TRY 105 million for electronic money institutions, with separately treated categories.

Does more capital allow more lending?

No. Own funds concern prudential resilience. Lending authority depends on the institution’s legal licence and statutory permissions.

Are payment and e-money companies subject to MASAK?

Yes. Electronic money institutions and most payment institutions must operate formal AML compliance programmes, subject to limited category-specific exceptions.

Does KVKK apply when payment data is shared with a lender?

Yes. The July 2026 payment/e-money sector guide specifically addresses personal data processing, controller/processor roles, transfers and security.

Do consumer credit rules apply to digital fintech loans?

Where the borrower is a consumer and the product constitutes consumer credit, the Turkish consumer-credit framework applies. Consumer credit may be concluded remotely, and consumers generally have a 14-day withdrawal right.

Conclusion: How Can Payment and E-Money Companies Participate in Lending Legally?

The principal rule governing fintech lending in Turkey is unusually clear.

Payment institutions cannot grant credit.

Law No. 6493 states this directly in Article 14.

Electronic money institutions cannot grant credit either.

Article 20 applies the same prohibition to EMIs.

The current Payment Services Regulation reinforces both prohibitions through Article 16.

An institution cannot grant credit.

It cannot create the impression through advertising that it grants credit.

It cannot instalment amounts whose payment it intermediates.

These rules establish a strong regulatory boundary between:

payments

and

lending.

The boundary is particularly important because modern fintech products increasingly blur that distinction from the customer’s perspective.

A digital wallet can look like a bank account.

A virtual IBAN can look like a current account.

A prepaid card can look like a debit card.

But the licence behind those services remains fundamentally different.

The fact that an EMI can provide:

• cards;
• wallets;
• accounts;
• transfers

does not allow it to add:

overdraft

or

consumer lending

merely as another application feature.

The same principle applies to a payment institution.

Merchant acquiring does not create merchant lending authority.

A payment account does not create an overdraft licence.

Payment processing does not permit the institution to finance the underlying purchase.

Article 16’s prohibition on instalmenting intermediary payment amounts is particularly important for BNPL.

A payment institution cannot simply pay a merchant today and turn the customer’s payment into four instalments payable to the payment institution.

That model moves from payment processing into financing.

The narrow telecommunications exception does not alter the general rule.

The Regulation expressly provides that specified payments billed through a telecommunications operator may be collected by the invoice due date without being treated as credit.

But the institution cannot pay or guarantee the merchant before the bill is collected, and the product is subject to detailed risk-management and transaction-limit requirements.

This exception therefore confirms rather than weakens the rule.

Where the regulator wished to distinguish a deferred payment mechanism from credit, it did so expressly.

For most fintech lending products, the practical solution is not to fight the credit prohibition.

It is to separate the roles correctly.

A sustainable structure may be:

Payment Institution / EMI → payment infrastructure and customer interface

Bank or Financing Company → regulated credit

This permits the fintech to remain deeply involved in the customer journey without unlawfully becoming the lender.

The fintech may provide:

• embedded credit application;
• payment processing;
• merchant integration;
• repayment collection;
• data analytics;
• technical scoring.

The regulated lender can remain responsible for:

• underwriting;
• funding;
• credit approval;
• loan agreement;
• credit risk.

Financing companies are particularly relevant to purchase finance.

The BDDK expressly describes financing companies as institutions financing purchases by paying sellers directly on behalf of buyers and subsequently receiving repayments from those borrowers.

This structure can provide a natural legal architecture for:

• BNPL;
• checkout finance;
• merchant-linked credit.

Banks provide another route.

An electronic money wallet can integrate credit from a bank while remaining responsible only for its authorised payment/e-money functions.

The essential requirement is that the customer understands:

who the creditor is.

That is also why marketing deserves special attention.

Article 16 expressly prohibits payment and e-money institutions from creating the impression that they themselves provide credit.

A co-branded loan therefore should not hide the regulated lender.

The user interface can be seamless.

The regulatory identity cannot be fictitious.

Data represents another valuable part of fintech lending.

Payment companies possess rich information concerning customer and merchant transactions.

Such information can make credit decisions:

• faster;
• more accurate;
• more automated.

But payment data is not legally ownerless information.

The KVKK Authority’s July 2026 Payment and Electronic Money Sector Good Practices Guide specifically addresses the processing and transfer of personal information in this sector.

A lending partnership should therefore distinguish:

data required for payment services

from

data used for credit scoring

from

data used for loan marketing.

MASAK compliance should likewise be coordinated.

Electronic money institutions and most payment institutions fall within the formal AML compliance-programme regime, as do financing companies.

A fintech ecosystem involving several regulated institutions therefore needs a clear allocation of:

• customer identification;
• risk monitoring;
• sanctions controls;
• suspicious transaction procedures.

Where consumers receive credit, consumer protection creates a further layer.

Turkish consumer-credit rules recognise remotely concluded credit agreements and provide consumers with significant mandatory protections, including a general 14-day withdrawal right.

Fintech lending should therefore be designed as:

digital credit

rather than

credit without legal formalities.

The customer can complete the entire borrowing process within seconds.

But the product should still provide legally required information and contractual protections.

For investors, the most important diligence question is often not:

“Does this fintech have a payment licence?”

It is:

“Who is actually financing the customer?”

The answer should be visible in:

• contracts;
• accounting;
• money flows;
• credit-risk allocation.

A company may describe itself as a payment institution while maintaining millions of lira of customer “advances.”

That deserves investigation.

Likewise, a merchant settlement product may be commercially labelled “early settlement” but economically operate as a loan against future turnover.

Substance should be tested carefully.

The best regulatory sequence for launching fintech lending in Türkiye is therefore:

identify the credit product → identify who funds it → determine who carries credit risk → select the authorised lender → separate payment and lending functions → structure customer contracts → review advertising → design repayment/payment flows → establish AML and KVKK allocation → launch.

The central rule can ultimately be expressed very simply:

Turkish payment regulation allows payment companies to move money. It does not allow them to manufacture credit from a payment licence.

A payment institution can become an important part of a lending ecosystem.

An electronic money wallet can become one of the most powerful credit-distribution channels in the market.

But the actual credit should remain with an institution legally authorised to lend.

For payment and e-money companies, the strategic opportunity is therefore not necessarily to become lenders themselves.

It is to become the technology, payment and distribution layer through which regulated lenders can reach customers efficiently.

That separation is the foundation of legally sustainable fintech lending in Turkey.

Legal Disclaimer: This publication provides general information concerning fintech lending, payment institutions, electronic money institutions, embedded lending, BNPL and financing-company regulation in Türkiye as of July 2026. It does not constitute legal, financial, tax or regulatory advice. The classification of an advance, settlement arrangement, overdraft, instalment, BNPL product or merchant-finance product depends on its actual economic and contractual structure. Each lending-related fintech model should therefore be individually reviewed under Law No. 6493, the current CBRT Payment Services Regulation, banking and financing-company legislation, consumer law, MASAK legislation and KVKK before launch.