Payment and e-money licence Turkey questions should begin with the business model, not with a generic “fintech licence” checklist. Under Law No. 6493, a company that will provide regulated payment services or issue electronic money in Türkiye must determine the exact service scope and obtain the relevant TCMB operating authorisation before carrying out the regulated activity.
The practical 2026 sequence is: map the customer/fund flow → classify the Law No. 6493 service → decide payment institution vs electronic-money institution → build the A.Ş., ownership and governance structure → prepare financial/technical/compliance evidence → apply through the current TCMB route → launch only within the authorised scope → maintain ongoing supervision compliance.
Quick Answer: Does Your Fintech Model Need a TCMB Licence?
| Business model |
First regulatory question |
Likely route |
| Merchant acquiring / payment acceptance |
Does the company itself provide a payment service under Article 12 of Law No. 6493? |
Payment-institution analysis. |
| Money transfer / remittance |
Who executes the payment transaction and contracts with the user? |
Payment-institution analysis. |
| Payment initiation / account information |
Does the company itself provide the regulated open-banking service or only technology to an authorised provider? |
TCMB service-scope analysis. |
| Digital wallet / stored monetary value |
Will the company issue electronic monetary value against funds received? |
Electronic-money-institution analysis. |
| Pure B2B software / fraud / API vendor |
Does the vendor itself hold funds, execute a payment service or contract for the regulated service? |
May be a technology-vendor model rather than a licensed institution; classify the substance. |
| Digital bank / deposit-taking model |
Is the activity banking rather than payment/e-money activity? |
Banking-authorisation assessment under the BDDK framework, rather than a TCMB payment/e-money application. |
| Crypto platform / custody |
Is the company a crypto-asset service provider? |
Crypto-asset authorisation assessment under the SPK framework, rather than a TCMB payment/e-money application. |
Use this guide when preparing the applicant company and operating-authorisation file for payment or electronic-money services. If the product’s regulatory category is still uncertain, start with the fintech regulatory map. If your company instead needs a provider to accept card payments for its own sales, use the Virtual POS merchant-onboarding guide; that is a different application from establishing the payment-service provider.
Classify the regulated service before choosing the TCMB authorisation scope.
1. Payment Institution and Electronic-Money Institution Are Different
TCMB publishes the payment services that each authorised payment institution may provide under Article 12 of Law No. 6493. The regulator also publishes a separate list for electronic-money institutions and their authorised payment-service scopes.
| Question |
Payment institution |
Electronic-money institution |
| Core regulatory role |
Provides one or more authorised payment services. |
May issue electronic money and provide the payment services included in its authorisation. |
| Licence scope |
Limited to the Article 12 services actually authorised by TCMB. |
Electronic-money issuance plus authorised payment-service scope. |
| Customer funds |
Fund flows and safeguarding depend on the authorised service. |
Electronic-money issuance creates its own safeguarding and operational obligations. |
| Financial requirement |
Category-specific financial and own-funds requirements apply. |
Higher current minimum own-funds requirement applies under the 2026 framework. |
Do not describe an e-money institution as simply a “bigger payment processor”. The legal product, fund flow, safeguarding model, accounting, technology and ongoing controls differ.
2. A Technology Company Is Not Automatically a Payment Institution
A SaaS or infrastructure vendor can provide technology to banks, payment institutions or e-money institutions without necessarily becoming the regulated provider itself. The boundary becomes more sensitive when the company:
- contracts directly with users for the regulated payment service;
- holds or controls customer funds;
- executes or initiates payment transactions in its own regulated capacity;
- issues stored monetary value;
- represents itself publicly as the payment/e-money institution;
- assumes functions reserved for an authorised institution.
Contract labels alone do not decide regulatory status. Draw the actual customer, contract, data and fund flows before incorporating or building the licence file.
3. Corporate Form: Current TCMB Rules Require an A.Ş.
TCMB’s current FAQ states that a payment institution and an electronic-money institution must be established in the form of a joint-stock company (Anonim Şirket / A.Ş.) and that the company and its shareholders must satisfy the statutory conditions applicable to the selected route.
This is a sector-specific requirement. It should not be confused with the general company-law rule that many ordinary Turkish businesses can choose between Ltd. Şti. and A.Ş.
Before MERSIS/Trade Registry filing, confirm at least:
- the exact requested payment-service/e-money scope;
- company purpose and trade-name wording;
- shareholding and ultimate beneficial owners;
- shareholder/manager eligibility and integrity criteria;
- capital and financial-resource plan;
- board/governance structure;
- internal control, risk and compliance functions required for the model.
For general corporate setup mechanics, use Company Formation in Turkey: 2026 Guide, but treat the TCMB conditions as the controlling sector layer.
4. 2026 Minimum Own-Funds Thresholds: Do Not Call Them a Universal Fintech Capital Number
The TCMB update published on 31 January 2026 changed the minimum own-funds obligations under the payment/e-money regulation, effective 30 June 2026. The current thresholds are:
| Regulated category |
Minimum own funds from 30 June 2026 |
Important qualification |
| Payment institution providing the service in Regulation Article 4/1-(e) |
TRY 20 million |
Category-specific rule; verify that the planned service actually falls in this category. |
| Other covered payment institutions |
TRY 40 million |
The regulation contains a stated exception for institutions exclusively providing the Article 4/1-(g) service; classify before applying the figure. |
| Electronic-money institution |
TRY 105 million |
Current minimum own-funds requirement; additional financial/licensing conditions can also apply. |
Do not confuse own funds with one simple incorporation deposit. A licence applicant must map all current statutory capital, paid-in-capital, own-funds and financial-sustainability conditions under the exact TCMB route. These amounts are time-sensitive and should be rechecked immediately before funding or filing.
5. Use the Official TCMB Application Route, Not an Old One-Page Checklist
TCMB’s Payment Services section publishes a dedicated document for the stages of payment and electronic-money institution operating-authorisation applications, a guide matching business models to payment-service types, the current secondary legislation and the live authorised-institution lists.
Start from the TCMB Payment Services portal.
A serious application file typically needs coordinated evidence across several workstreams rather than a generic bundle of corporate documents:
- regulated business model: product, fund flow, customers, transaction types and requested Article 12 scope;
- corporate: A.Ş. records, articles, ownership, UBO and governance;
- shareholder/management suitability: statutory qualification and integrity evidence;
- financial: funding source, financial forecasts, capital/own-funds and sustainability;
- operations: organisational model, roles, outsourcing and service processes;
- risk/internal controls: risk management, internal control, compliance and audit readiness;
- information systems: architecture, security, access, continuity, logging, testing and vendor controls;
- customer-money protection: safeguarding/account separation and reconciliation controls where applicable;
- AML/CFT: customer identification, risk classification, transaction monitoring, suspicious-transaction processes and MASAK obligations.
A TCMB authorisation file is a connected corporate, financial, operational and technology evidence package.
6. Do Not Publish a Fixed Universal Approval Timeline
There is no reliable public rule that every payment/e-money application will be completed in a fixed “12–18 month” window. The actual process depends on the licence scope, completeness of evidence, regulatory questions, corporate/financial readiness, information-system work and applicant response times.
Build the project around dependencies, not a guaranteed date:
- service classification;
- corporate/shareholder readiness;
- funding and own-funds plan;
- business/financial plan;
- technical architecture;
- internal-control and AML framework;
- formal application stages;
- responses/remediation;
- authorisation decision;
- production launch within authorised scope.
Likewise, do not reuse a 2024 application-fee number. Check the current TCMB tariff/official filing requirements at the time of application.
7. Information Systems Are Part of the Licence Architecture
TCMB’s payment-services framework includes a dedicated communique governing information systems of payment/e-money institutions and payment-services data-sharing services. Technology cannot be treated as a post-licence implementation detail.
Pre-application technical diligence should cover:
- system/network architecture and data flows;
- authentication and transaction security;
- privileged-access management;
- encryption and key management;
- logging/audit trail;
- vulnerability and penetration testing;
- outsourcing/cloud/vendor responsibilities;
- incident response;
- business continuity/disaster recovery;
- independent audit and reporting requirements where applicable;
- open-banking/data-sharing interfaces where in scope.
Do not commit to a cloud, outsourcing or core-platform contract before confirming that the architecture can satisfy the exact regulated route.
8. MASAK AML/KYC Is an Ongoing Operating Obligation
Payment and electronic-money institutions are within Türkiye’s AML/CFT framework where the applicable MASAK rules make them obliged parties. A compliant setup can require more than collecting an ID document at onboarding.
Map:
- customer and beneficial-owner identification;
- remote-onboarding method where applicable;
- risk scoring;
- PEP/high-risk relationship controls;
- transaction monitoring;
- suspicious-transaction escalation/reporting;
- tipping-off restrictions;
- record retention;
- training, internal control, risk management and compliance-program requirements where triggered.
The exact programme should be designed with appropriately qualified AML/legal professionals using current MASAK guidance.
September 2026 remote-onboarding update: Rules published on 4 September 2026 expanded and clarified remote customer identification for payment and electronic-money providers. The framework now expressly addresses biometric methods/electronic identity-capable documents, makes NFC-based verification the primary identity-document check in the relevant remote-identification flow, and permits non-Turkish natural persons to be identified remotely with an ICAO 9303-compliant, NFC-enabled passport under the applicable MASAK framework. This is an onboarding-method update, not a relaxation of AML/KYC duties; institutions still need to apply the current identity-verification, recordkeeping and risk controls that fit the customer and transaction.
9. Authorisation Is Scope-Specific
TCMB’s live lists show the exact Article 12 services each institution may provide. A licence is therefore not an unlimited right to launch every future payment product.
Before adding a product, changing the fund flow, acquiring a new regulated capability or materially restructuring the company, check whether the change triggers:
- licence-scope expansion;
- regulatory approval/notification;
- share-transfer or qualified-holding controls;
- governance changes;
- new financial/own-funds consequences;
- new information-system or outsourcing controls;
- new AML/consumer obligations.
10. Post-Licence Supervision Is Material
TCMB’s 29 January 2026 release on its 2025 supervision provides a useful dated indicator of enforcement intensity: the Bank reported 7 operating-licence revocations and 14 temporary suspensions, as well as other supervisory measures and administrative penalties.
This is not a failure-rate statistic and should not be used to predict an applicant’s outcome. It shows why a licence must be supported by ongoing governance, financial, safeguarding, technology, reporting, AML and consumer compliance.
Operating authorisation is the start of regulated supervision, not the end of compliance.
11. Check the Provider on TCMB’s Live Lists
Before a merchant, investor, bank, vendor or customer relies on a payment/e-money provider, check the official TCMB list. TCMB publishes:
- authorised payment institutions and their service scopes;
- authorised electronic-money institutions and their service scopes;
- suspended/revoked status information.
This live verification is more reliable than an old third-party “licensed fintech” directory.
12. Pre-Incorporation Go / Fix / Stop Test
| Status |
What it means |
Next action |
| GO |
Service scope, A.Ş. structure, shareholders, funding, technology and compliance path are mapped to the current TCMB route. |
Build the application evidence plan and sequence incorporation/funding around it. |
| FIX |
Regulated function is clear but ownership, financial resources, vendor architecture, AML or information-system design is incomplete. |
Resolve the identified gate before irreversible spend. |
| STOP / RECLASSIFY |
The model may actually be digital banking, crypto/capital-markets activity, or only an unregulated technology-vendor role. |
Return to the regulator map before filing a TCMB payment/e-money application. |
For a regulated payment/e-money project, define the TCMB route before finalising the company and technology stack.
How Workon Can Support the Readiness Process
Workon can coordinate Turkish company-formation readiness, foreign shareholder documents, registered-address/workspace setup, bank-account application support and the operational handoff to appropriately qualified fintech regulatory, legal, AML, cybersecurity and tax professionals. TCMB alone decides operating authorisation. Workon does not issue payment/e-money licences, provide regulated financial services or guarantee approval.
Key Takeaways
- This page covers TCMB payment/e-money authorisation, not every fintech licence in Türkiye.
- Payment and electronic-money institutions must use the A.Ş. form under the current Law No. 6493 framework.
- TCMB authorises specific payment-service scopes rather than one unlimited fintech licence.
- From 30 June 2026, current minimum own-funds figures are TRY 20m / TRY 40m / TRY 105m depending on the regulated category.
- Those figures are regime-specific own-funds obligations, not a universal startup-capital table.
- Use the current TCMB application stages and business-model guide rather than an old generic application checklist.
- Do not promise a fixed approval timeline or reuse an outdated application fee.
- Information systems, safeguarding, AML/KYC, governance and financial controls continue after authorisation.
- Always verify an institution and its exact scope on TCMB’s live lists.
The Central Bank of the Republic of Turkey, TCMB, is the operating-authorisation and supervision authority for payment and electronic-money institutions under Law No. 6493. Banking, crypto or other financial models can instead fall under BDDK, SPK or another regulator.
No. The actual customer, contract, data and fund flows control the classification. A pure technology vendor may not be the regulated provider, while a company that contracts for payment services, holds or controls customer funds, executes regulated transactions or issues stored monetary value can enter the TCMB perimeter.
Under the current TCMB framework, payment institutions and electronic-money institutions must be established as joint-stock companies, A.Ş., and the company and shareholders must satisfy the statutory conditions for the requested route.
From 30 June 2026, the current minimum own-funds figures are TRY 20 million for the specified Article 4\/1-(e) payment category, TRY 40 million for other covered payment institutions subject to the stated exception, and TRY 105 million for electronic-money institutions. These are category-specific regulatory own-funds requirements, not a universal startup-capital number.
There is no reliable universal 12–18 month or other fixed approval promise. Timing depends on licence scope, corporate and shareholder readiness, financial resources, technology and information systems, AML and internal controls, application completeness and regulatory questions or remediation.
No. Authorisation is scope-specific. TCMB’s live lists identify the payment services each institution may provide, and a new product, fund flow, ownership change or material restructuring can require additional approval, notification or compliance analysis.
Important: Last reviewed 17 September 2026. This guide provides general information on payment and electronic-money authorisation in Türkiye and is not legal, financial-regulatory, AML, cybersecurity, tax or investment advice. Service classification, company/shareholder conditions, capital and own-funds requirements, fees, application evidence, technology controls and ongoing obligations can change. Confirm the proposed model against current Law No. 6493, TCMB regulations, official application guidance and appropriately licensed/qualified professionals before incorporating, funding the applicant or offering regulated services. Workon coordinates setup and operational readiness but does not issue TCMB licences or provide regulated payment/e-money services.
