What licenses do Turkish payment service providers need to operate, and how long does the authorization process take?
Lawyer Answers
Serka Law Firm
Which authorization applies. In most cases, a provider that performs payment services needs authorization as a payment institution. If the model also stores value and later redeems it, that usually moves the business into electronic money institution territory. Both are authorized and supervised by the Central Bank of the Republic of Türkiye under Law No. 6493.
Who issues it. Not a ministry, not a generic trade office, and not a one-form portal. The CBRT is the licensing authority, and the file is not just corporate paperwork. It is a full regulatory build: corporate structure, paid-in capital, shareholder fitness, governance, internal control, risk management, information systems, complaints handling, safeguarding architecture, and operational readiness.
How long it takes. The law says the CBRT should decide within six months after the required information and documents are complete. But that statutory clock is not the same thing as real launch timing. The CBRT’s published process is staged: application, preliminary review, intelligence review, final certification, collateral and fee completion, and Official Gazette publication. In other words, the process is measured not just by calendar time, but by how regulator-ready the business already is when it files.
What it costs. The first serious cost is not legal drafting, it is capital. Until 30 June 2026, current minimum own-funds thresholds are TRY 15 million for payment institutions limited to bill-payment intermediation, TRY 30 million for other payment institutions, and TRY 80 million for electronic money institutions. From 30 June 2026, these rise to TRY 20 million, TRY 40 million and TRY 105 million. On top of that, the CBRT’s licensing guide states a TRY 5,00,000 application fee and a TRY 1,000,000 licence fee, plus the related legal charges.
What ongoing compliance really means. Licensing is only the opening gate. A Turkish PSP must continuously protect customer funds, keep relevant records in Türkiye for at least ten years, maintain information systems and audit trails, establish internal control, risk, accounting and reporting systems, undergo independent information-systems audits, and operate as a MASAK-obliged entity for AML/CFT purposes, including suspicious transaction reporting.
The hidden trap. The biggest licensing mistake is describing the product as a marketplace, gateway, wallet, super-app, or technical integrator without mapping the actual money flow. In Türkiye, the regulator looks through branding and asks one practical question: who receives, controls, instructs, safeguards, or redeems the funds. That answer determines the licence perimeter.
Bottom line. If the business will touch payment flows, do the legal classification before building the commercial stack. In this sector, the fastest way to lose a year is to build first and discover later that the regulator sees the model as a licensed payment institution or electronic money issuer.
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