In Turkey, payment services and electronic money issuance are governed by Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions. Following a 2020 reform, regulatory and supervisory authority over the sector was transferred to the Central Bank of the Republic of Turkey (CBRT). Accordingly, license applications are made to the CBRT — not the banking regulator — and are processed under the CBRT's secondary legislation.
Payment Institution or E-Money Institution?
The first and most critical decision is which type of institution to operate as:
- Payment Institution: Provides payment services such as money remittance, payment order initiation, account information services and merchant acquiring. It cannot issue electronic money.
- Electronic Money Institution: In addition to payment services, it may issue electronic money — covering prepaid cards, digital wallets and stored-balance models. Its obligations and minimum capital threshold are higher.
If your business model involves holding customer balances, offering a digital wallet or issuing closed/open-loop prepaid products, you will need an e-money institution license. If you merely intermediate the payment flow, a payment institution license may suffice.
The Application Process Step by Step
The licensing process rests on a well-prepared application file. The general flow is:
- Pre-assessment and feasibility: Designing the business model in line with the legislation and correctly classifying the service types.
- Company formation: Incorporation as a joint-stock company, with a shareholding structure that meets the qualifications required of founders.
- Capital: Payment of the minimum paid-in capital in cash and free of any collusion. The minimum amount varies by institution type and may be updated in the legislation, so the current figure should be verified before applying.
- Corporate infrastructure: Establishing information systems, internal control, risk management, internal audit and compliance functions; independent audit and penetration-test reports.
- Application file: Submitting the business plan, budget projections, organisational chart, policies and procedures, AML compliance programme and information-systems documentation to the CBRT.
- Review and operating permit: CBRT review, remedying of deficiencies and obtaining the final operating permit.
Qualifications Required of Founders and Managers
Founding shareholders and board members are assessed against integrity, financial strength and reputation criteria; the absence of convictions for certain offences, the requisite professional experience and prescribed education requirements are evaluated. Qualified shareholders are expected to document the source of their funds transparently.
Timeline and Common Mistakes
Depending on the completeness of the file, the process is generally completed within a few months to a year. The most common causes of delay are misclassification of the service type, insufficient information-systems documentation, internal control and compliance policies that remain at a template level, and inadequate documentation of the capital source.
How FinWise Consulting Helps
Our team consists of experts with many years of service at the regulator. Across payment and e-money licensing, we provide end-to-end support — from designing the business model and preparing the application file to maintaining compliance obligations after the operating permit is granted. A properly structured application both shortens the timeline and reduces the risk of rejection.
