Turkey Payments Operator Guide: Licensing, Direct Acquiring, and TROY

Turkey's payments market page covers the landscape operators actually see at checkout — FAST's rail mechanics, BKM's overlay services, TROY's adoption numbers, Papara and Paycell, and a licensing skeleton pointing to a 12–18 month timeline. What it doesn't cover is what a foreign operator needs before writing that timeline into a launch plan: the actual capital figures behind each licence tier, whether direct cross-border acquiring is even legally available, and the checkout-level constraints — taksit caps, mandatory lira settlement — that shape unit economics regardless of licensing route. This piece works from TCMB's own implementing regulation, not summaries of it, and says plainly where the public record runs out.

The regulator split operators get wrong

Turkey's payment-licensing framework has one structural feature that trips up operators coming from single-regulator markets: TCMB (Türkiye Cumhuriyet Merkez Bankası, the central bank) and BDDK (Bankacılık Düzenleme ve Denetleme Kurumu, the banking regulator) are not interchangeable, and they don't split authority the way a market page's "TCMB + BDDK" shorthand implies.

TCMB is the sole licensing authority for the two tiers that matter for a foreign entrant: Ödeme Kuruluşu (Payment Institution) and Elektronik Para Kuruluşu (Electronic Money Institution), both created under Law No. 6493 and detailed in TCMB's implementing regulation, the Ödeme Hizmetleri ve Elektronik Para İhracı ile Ödeme Hizmeti Sağlayıcıları Hakkında Yönetmelik (Official Gazette No. 31676, 1 December 2021, amended repeatedly through 19 March 2026). Throughout that regulation, "Banka" — the entity granting licences, running FAST, and setting capital rules — means TCMB, not a commercial bank. BDDK, separately, licenses and supervises commercial banks under Banking Law No. 5411, regulates card-scheme companies (kartlı sistem kuruluşu) under the Bank Cards and Credit Cards Law No. 5464, and — as covered below — sets credit-card instalment rules under that same 5464 framework. An operator planning a Turkish entry needs a TCMB payment-institution or e-money-institution licence, or a relationship with an entity that holds one, or a banking relationship; BDDK becomes relevant specifically for taksit rules and, if the operator becomes a bank, for prudential supervision.

TCMB's own regulation confirms this second track exists by cross-reference: its definitions section points to "kartlı sistem kuruluşu" (card-scheme company) as a term defined under Law No. 5464 rather than under Law No. 6493, and requires card-acquiring PSPs to ensure their acceptance infrastructure stays compatible with whichever scheme companies operate under that BDDK-administered framework. In practice this means a foreign entity evaluating Turkish card acceptance is dealing with two distinct compliance surfaces even before scheme-level commercial terms enter the picture: a TCMB licence (or a licensed partner) to acquire at all, and a separate, BDDK-administered card-scheme framework under Law No. 5464 governing how any domestic or international scheme operates.

Licence tiers, with actual capital figures

TCMB's regulation applies two separate capital tests, and conflating them is the most common way an operator misreads the licensing cost. The first is initial paid-in capital, required to file a faaliyet izni (operating licence) application at all. Article 11(2) sets this by activity scope: TRY 1 million for an applicant offering only bill-payment intermediation (fatura ödemesi), TRY 2 million for other payment services — which includes card acceptance and issuance — and TRY 5 million to issue electronic money. This is a one-time bar to clear at application.

The second test, minimum ongoing equity (asgari özkaynak) under Article 33, is a running solvency floor recalculated every June and December against the institution's actual payment volume, and reassessed each January by TCMB against Turkish inflation. At the regulation's 2021 baseline, these floors sat at TRY 3 million (bill-payment-only institutions), TRY 5 million (other payment institutions), and TRY 13 million (e-money institutions). Turkish inflation has since pushed them materially higher: a Communiqué published in Official Gazette No. 32798 on 30 January 2025, effective 30 June 2025, reset the floors to TRY 15 million, TRY 30 million, and TRY 80 million respectively — a five-to-six-fold increase from baseline in under four years, and the figure an operator should budget against, not the 2021 numbers still quoted in older commentary. TCMB's Article 33(3) formula also layers an additional equity requirement on top of these floors as payment volume scales, calculated in bands (4% of the first TRY 50 million in monthly payment volume, stepping down to 0.25% above TRY 500 million), multiplied by a factor that itself rises with volume tier — so a high-volume acquirer's actual ongoing equity requirement runs well above the headline floor.

Two structural points sit underneath these numbers. First, both capital tests are denominated and posted in Turkish lira, held with a Turkish bank — there's no route to satisfy them with a foreign-currency parent guarantee. Second, TCMB layers a separate teminat (collateral/guarantee deposit) requirement on top of equity under Article 36, running TRY 2–5 million depending on licence type before volume-based add-ons, plus TRY 500,000 per thousand agents used — a cost line distinct from the equity floor and easy to under-budget if an operator only prices the headline capital figures.

The application process itself carries its own fees, layered on top of the capital tests rather than substituting for them. Article 11(1) sets a non-refundable application fee of TRY 500,000, paid before TCMB opens the istihbari inceleme (background-review) stage of a two-step process; a positive outcome there leads to the nihai onay (final approval) stage, where TCMB inspects the applicant's governance structure, staffing, office, and technical systems in person before granting the licence. Article 11(16) adds a separate one-time licence fee of TRY 1,000,000, due within ten days of the institution actually starting operations — a cost distinct from, and additional to, the capital and equity figures above. None of these fees is refunded if the application fails at any stage.

The load-bearing question: can a foreign PSP acquire directly?

No — and the answer sits in a single, explicit clause rather than an inference from licensing generalities. Article 4(2) of TCMB's regulation lists exactly four categories of entity permitted to perform the payment services enumerated in Article 4(1): TCMB itself, banks licensed under Banking Law No. 5411, TCMB-licensed institutions incorporated in Turkey, and PTT (the state postal operator) acting under its own postal-services authority. Card acceptance and issuance — "ödeme aracının ihraç veya kabulü" — is itself one of the listed payment services, under Article 4(1)(c). A foreign PSP with no Turkish entity and no TCMB licence does not fit any of the four permitted categories. It cannot acquire a Turkish-resident cardholder's transaction directly from outside Turkey under its home-market authorisation, full stop — there is no cross-border passporting mechanism analogous to an EU PSP operating under a single EU licence across member states.

This puts Turkey structurally closer to South Korea, where the Electronic Financial Transactions Act routes Korean-issued cards through a licensed Korean payment gateway with no foreign-acquirer exception, than to markets where cross-border acquiring is the unrestricted default and local licensing is an optimisation. The practical routes for a foreign operator are the same two that recur across this pattern — covered in general terms in the local acquiring vs cross-border operator reference — but with Turkey-specific mechanics:

Incorporate and licence directly. Set up a Turkish anonim şirket (joint-stock company), file the two-stage TCMB application (istihbari inceleme — background review, then nihai onay — final approval), and meet the capital and equity figures above. Foreign ownership of that Turkish entity is explicitly accommodated, not barred: Article 11(14) requires additional documentation when a qualified shareholder (10%+) or controller of the applicant is itself a foreign bank or financial institution — an authorisation decision from its home regulator permitting Turkish operations, its latest consolidated audit report, confirmation it faces no restriction in its home jurisdiction, and detail on its international activity. This is a due-diligence gate on the foreign shareholder's own standing, not a nationality cap on ownership. iyzico's PayPal ownership and Papara's foreign-capital structure both operate inside this framework — there is no tier reserved exclusively for Turkish nationals comparable to Ghana's PSP-Standard licence.

Route through an already-licensed Turkish entity. For most foreign operators below the volume that justifies direct licensing, the practical path is a commercial relationship with a Turkish-incorporated PSP that already holds the TCMB licence — iyzico, PayU Turkey, Garanti BBVA Pay, or a Turkish-licensed entity operated by a global acquirer such as Adyen, Stripe, or Checkout.com. This is the same PSP-mediated pattern that dominates entry into Korea, Indonesia, and other markets where direct cross-border acquiring isn't legally available — the operator gets Turkish acceptance without incorporating, at the cost of a commercial margin and less control over settlement terms.

FAST: direct participation exists, but PSP-mediated access is still the default

FAST launched under exclusive bank participation in January 2021. That changed in 2023: TCMB Press Release 2022-53 confirms payment and electronic money institutions meeting the required conditions would gain direct FAST participation that year, ending the bank-only era for real-time transfers. Direct participation, though, is not a checkbox — it requires Trade Registry documentation and notarised signature circulars filed with TCMB, TCMB Management Committee approval, a signed FAST System Participant Agreement, an account held directly with TCMB, and passing TCMB's own technical certification process before connecting. For a newly licensed Turkish payment institution, that's a materially heavier build than integrating with a PSP that already holds direct FAST access and exposes it as an API.

The practical implication for most foreign-owned operators mirrors the acquiring question above: unless Turkish real-time-payment volume is large enough to justify the direct-participation build, routing FAST acceptance through an already-connected PSP — the same iyzico/PayU/bank-affiliated-gateway list relevant to card acquiring — is the faster and lower-overhead path. A March 2025 amendment adds a further wrinkle worth flagging for anyone building toward direct participation: institutions that hold customer payment accounts with direct online access, and that rank among the top ten by 2024 payment volume among non-FAST-participants, must expose account-access infrastructure to licensed payment-initiation and account-information providers via BKM by the end of 2025 — an open-banking-style obligation that scales in with size, not something a small new entrant needs to plan around immediately.

TROY: what's confirmed, and what this research could not source

BKM (Bankalararası Kart Merkezi) owns and operates TROY, and every card-acquiring PSP in Turkey — regardless of which international scheme it also carries — must register merchants through BKM's mandatory İşyeri Kayıt Sistemi (Merchant Registry System) under Article 9 of TCMB's regulation; a merchant cannot lawfully be onboarded for any card-based payment method without a BKM-issued işyeri kodu. TCMB's regulation also confirms BKM runs a formal technical certification and evaluation process (Article 59) for PSPs offering payment-initiation and account-information services, with results published on BKM's own site.

What this research could not confirm from a retrieved primary or credible secondary source is the specific commercial and technical requirements a foreign acquirer would need to meet for TROY-specific routing — a formal BIN-sponsorship arrangement, scheme membership fees, or certification steps distinct from the general İşyeri Kayıt Sistemi and open-banking certification covered above. BKM's own public documentation search returned scheme overview material and general merchant-registry rules, not a published TROY membership or sponsorship schedule for non-Turkish acquirers. An operator that specifically needs TROY-level routing economics — as distinct from simply accepting TROY-badged cards through a Turkish PSP's existing rails, which any licensed PSP can already do — should treat this as a direct commercial question to put to BKM or a Turkish acquiring partner, not something this guide or the market page can resolve from public sourcing.

Taksit: a checkout constraint with real numbers, not one paragraph

Turkey's instalment culture is well known qualitatively; what operators building checkout logic need is the regulatory mechanism and its current shape. BDDK — not TCMB — sets instalment (taksit) caps and outright prohibitions under Law No. 5464, via periodically revised Board Decisions rather than a single static rule. BDDK's own published decision index confirms this is an actively maintained series, not a fixed rule — decisions dated across 2019, 2020, 2021, 2023, and later years each adjusted specific caps.

Direct extraction of BDDK's own Board Decisions confirms the general ceiling for instalment sales of goods and services other than housing at 12 months for individual credit cards (corporate cards run to 18 months). Below that general ceiling, several categories carry their own, independently-set caps: furniture, white goods, and health products sit at 9 months; consumer electronics (excluding lower-priced televisions) at 4 months; televisions priced up to TRY 5,000 at 9 months; and tablets and club or association dues at 6 months — each fixed by its own Board Decision under the same Article 26(7) of the Bank Cards and Credit Cards Regulation, and each liable to move again. A defined set of categories is excluded from instalment sale entirely: telecommunications bills, direct-marketing purchases, bullion or bar-form jewellery, food, groceries, alcoholic beverages, fuel, cosmetics, office supplies, gift cards and vouchers, and purchases made outside Turkey generally — with a narrower, separate prohibition specifically on foreign airline, travel-agency, and accommodation spend that carves out Northern Cyprus at a 3-month cap rather than a blanket exemption for all foreign merchants. One widely-repeated figure does not hold up: claims that education and tuition instalments run to a 12-month cap trace to a 2015 change that bundled tuition with furniture and white-goods terms at the time. BDDK's current, consolidated decision record carries no distinct education or tuition category at all, and the furniture/white-goods cap it was bundled with in 2015 has since been reduced twice, to the 9 months confirmed above — so that figure is stale and is omitted here rather than repeated.

The operator consequence is concrete either way: for consumer-facing checkout above a mid-ticket threshold, Turkish buyers expect to see instalment options as a standard field, not a premium feature, and a foreign merchant whose PSP integration doesn't surface taksit terms is competing on price alone against domestic merchants who don't have to. Because the caps move by regulator decision rather than statute, build the checkout logic to pull current limits from the acquiring PSP's own rate card — which reflects BDDK's latest decision — rather than hard-coding figures from any published guide, including this one.

FX and lira settlement for a foreign merchant

Three separate rules govern how money moves once a foreign operator is either licensed directly or routed through a Turkish PSP. First, Article 66(3) requires a licensed kuruluş to execute a payment purely in Turkish lira whenever both the sender and receiver are Turkey-resident using Turkey-based payment service providers — a foreign merchant's Turkish-resident-customer sales, once inside a Turkish PSP's acquiring rails, settle domestically in TRY with no FX leg available through that rail. Second, Article 66(4) bars a kuruluş from opening foreign-currency payment accounts for Turkey-resident customers or holding FX balances in them, subject to narrow, short-duration exceptions tied to a genuinely cross-border payment passing through — reinforcing that domestic settlement stays lira-denominated by design, not merchant preference. Third, converting settled TRY proceeds and moving them out of Turkey is a separate step from acquiring settlement itself, governed by Turkey's Foreign Direct Investment Law No. 4875 rather than the payment-services regulation: foreign investors may freely transfer net profits, dividends, and liquidation proceeds abroad through banks once applicable corporate and withholding tax is settled, with no blanket repatriation cap for an ordinary operating business.

The practical sequence for a foreign merchant is therefore: acceptance and settlement happen in TRY inside Turkey regardless of the merchant's own invoicing currency; a separate FX conversion and cross-border transfer step follows, typically through the merchant's own banking relationship or its parent-company treasury function rather than through the payment institution itself; and Turkish corporate tax and dividend withholding apply before funds leave. Operators used to markets where the acquirer or PSP handles FX conversion as part of settlement should not assume that model transfers to Turkey — plan for a distinct treasury step, and for lira volatility risk sitting on the merchant's own book between settlement and conversion, not the PSP's.

What changed recently — and what to watch

TCMB has amended this regulation ten times since its December 2021 publication, most recently on 19 March 2026 (Official Gazette No. 33201). That amendment added Article 36/A, permitting payment and e-money institutions to place customer safeguarded funds — held in bank-controlled protection accounts under Articles 34–35 — into overnight yield-bearing arrangements, with net yield after the holding bank's commission credited back to the protection account and made available for the institution's own use, while principal protection and same-day liquidity for the institution's payment obligations stay mandatory. This puts Turkey in the same live regulatory conversation as the UK and EU around whether and how e-money and payment institutions can earn yield on customer-safeguarded funds — worth tracking for any operator building treasury assumptions around a Turkish e-money balance sheet.

Two earlier 2025 amendments are also directly operator-relevant. The 30 January 2025 Communiqué covered above reset the minimum-equity floors that anchor licensing cost. A 28 March 2025 amendment added the open-banking-style account-access obligation described in the FAST section — relevant primarily to larger, established institutions rather than new entrants, but a signal that TCMB is actively building third-party payment-initiation infrastructure around BKM's technical certification role, not leaving it static. An operator evaluating Turkey on anything beyond a one-time snapshot should check TCMB's own amendment history table at the foot of the regulation before finalising capital or compliance planning — the pace of revision here is materially faster than a "check back annually" cadence would catch.

What this means for operators

Budget the current capital figures, not the 2021 baseline. TRY 15–80 million in ongoing minimum equity, reassessed every January against inflation, plus a separate TRY 2–5 million-plus collateral deposit under Article 36 and the TRY 500,000 application plus TRY 1,000,000 licence fee — figures that keep moving upward and that a stale blog post will understate.

Accept that direct cross-border acquiring is not on the table. Article 4(2) is explicit; the only paths are Turkish incorporation with a TCMB licence, or a commercial relationship with an already-licensed Turkish PSP or bank. Foreign ownership of the licensed entity is workable and precedented — it is not the blocker.

Treat FAST direct participation as a scale decision, not a default. PSP-mediated access covers most foreign-operator use cases; direct participation's approval, agreement, and certification burden only pays off at real Turkish real-time-payment volume.

Design checkout around taksit as infrastructure, not a nice-to-have. A 12-month general instalment ceiling on individual cards, lower category-specific caps for furniture/white goods (9 months) and electronics (4 months), and a fixed list of excluded categories are the numbers to encode — pulled live from the acquiring PSP's rate card given how often BDDK revises the specifics.

Plan FX and repatriation as a treasury step separate from acquiring settlement. TRY-only domestic settlement is structural, not negotiable; profit repatriation runs through Foreign Direct Investment Law No. 4875 and ordinary tax compliance, not through the payment institution's own rails.

Confirm TROY-specific routing economics directly with BKM or a Turkish acquiring partner. This is the one area this research could not resolve from public sourcing — treat any published BIN-sponsorship figure for TROY with the same scepticism this guide applied to its own gaps.