Pursuant to the “Regulation Amending the Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers” (“Regulation“) and the “Communiqué Amending the Communiqué on Information Systems of Payment and Electronic Money Institutions and Data Sharing Services of Payment Service Providers in the Field of Payment Services” (“Communiqué“) published in the Official Gazette dated April 29, 2023 and numbered 32175, the deadline for the compliance by payment institutions and electronic money institutions with some of the provisions of the legislation, has been extended from April 30, 2023 to June 30, 2023.

In this regard, the following is a brief list of some of the obligations that must be fulfilled until June 30, 2023 by the payment institutions and electronic money institutions operating as of December 1, 2021:

  • Institutions engaging in intermediation activities with respect to invoice payments must have a share capital of at least 1 million Turkish Liras;
  • Institutions that perform transactions such as money transfers, remittance, operation of payment accounts, etc. must have a share capital of at least 2 million Turkish Liras;
  • The title of the company applying for the activity permit must include the phrase “payment institution” or “electronic money institution”;
  • The company wishing to act as an electronic money institution or a payment institution must file an application before the Central Bank of the Republic of Turkey (“CBRT“), in relation to 2 stages namely the “intelligence examination stage” and the “final approval stage”;
  • The company must not give the impression that it operates as a bank or performs transactions on behalf of a bank;
  • The company may conduct foreign exchange transactions only when at least one of the parties of the relevant transaction is located abroad; and
  • The company must provide CBRT with the amount of collateral determined on the basis of the number of customers.

The Communiqué and the Regulation entered into force on April 29, 2023.

Bahar Ülgen Hasşerbetçi
Partner | [email protected]
Ece Kipri
Associate | [email protected]