Fintech in Türkiye 2026 - trends and developments

Introduction

The fintech sector in Türkiye has been developing steadily over the past several years, with growth accelerating significantly in recent times in parallel with global developments. The number of market players continues to increase, start-ups are making substantial contributions to the ecosystem, and public adoption rates are steadily rising. Against this backdrop, the sector is undergoing a transformative period characterised by expanding market activity and the introduction of new regulatory frameworks.

According to a press release from the Investment and Finance Office of the Presidency of the Republic of Türkiye in October 2025, the Turkish fintech sector reached a significant turning point in 2025 and achieved strong growth momentum. In the first months of the year alone, the sector attracted USD201.3 million in investments, surpassing the total investment volume of USD196.1 million recorded throughout 2024.

In parallel, traditional financial institutions, particularly banking institutions, have expanded their business models by implementing fintech-based solutions. As a result, the financial services landscape has evolved into a more sophisticated and layered structure encompassing digital banking, open banking frameworks, payment services and crypto-asset-related services. Alongside this institutional transformation, a growing number of independent fintech companies and start-ups have emerged, focusing specifically on these verticals and contributing to rapid innovation and increased competition within the ecosystem.

There are also incentives available for fintech companies. As set out under the 2024–2028 Twelfth Development Plan on the Development of Financial Services published by the Presidency of the Republic of Türkiye, Strategy and Budget Directorate, it was envisaged that the range of incentives accessible through simpler and more streamlined application processes would be expanded.

This growth, supported by incentive mechanisms, has also been further reinforced by increasing regulatory clarity. The regulatory framework continues to evolve under the oversight of the Central Bank of the Republic of Türkiye (CBRT), the Banking Regulation and Supervision Agency (BRSA) and the Capital Markets Board (CMB), contributing to a more robust, secure and well-regulated fintech ecosystem.

In this context, the key trends and developments in the Turkish fintech market may be analysed under four main areas.

1. Banking

According to data published by the Banks Association of Türkiye in September 2025, a total of 68 banks operate in Türkiye, comprising 38 deposit banks, 21 development and investment banks, and nine participation banks. Banks are primarily governed by the Banking Law No. 5411 (“Banking Law”) and extensive secondary legislation, and are regulated and supervised through resolutions, and instructions issued by the BRSA and the CBRT.

Trends in the banking sector and newly regulated business models are also evolving and will be addressed under three main categories: (i) open banking, (ii) digital banking and (iii) Banking-as-a Service (BaaS).

1.1 Open banking

1.1.1 Regulatory framework

In parallel with payment initiation service providers (PISPs) and account information service providers (AISPs) regulated under EU Payment Services Directive 2 (PSD2), amendments introduced in January 2020 to Law No. 6493 on Payment and Security Settlement Systems, Payment Services and Electronic Money Institutions (“Payment Services Law”) brought similar services within the scope of Turkish payment services legislation. With these amendments, payment initiation services enabling the initiation of a payment order from a payment account held with another payment service provider upon the request of the payment service user, as well as account information services allowing the online presentation of consolidated information relating to one or more payment accounts held with payment service providers, subject to the explicit consent of the payment service user, were formally recognised as payment services. These changes laid the initial legal foundation for open banking in Türkiye.

Subsequently, in July 2020, open banking services were formally regulated and defined through the Regulation on Banks’ Information Systems and Electronic Banking Services issued by the BRSA. Under this regulation, open banking services are explicitly defined as electronic distribution channels where customers or parties acting on behalf of customers can remotely access financial services offered by banks through methods such as API, web services or file transfer protocols to conduct banking transactions or give instructions to the bank. Open banking services are recognised as part of electronic banking services and subject to requirements such as customer authentication. Subsequently, data sharing in payment services was further regulated through the Guideline on Data Sharing Services in Payment Services issued by the CBRT in April 2023.

1.1.2 Implementation

The Interbank Card Center (BKM) acts as a technical service provider, undertaking an intermediary role. Banks acting as account service providers will connect to the BKM through their application programming interfaces and will share customer data via BKM, subject to the explicit consent of the customers. Fintech entities providing account information services (AISPs) and payment initiation services (PISPs) will be able to obtain customer data directly from BKM.

BKM is responsible for verifying whether the relevant fintech entity has obtained the required activity permits and licences and whether it complies with the applicable technical and operational requirements. Customer data will be shared only with entities that are duly authorised and licensed.

1.2 Digital banking

1.2.1 Regulatory framework

Digital banking is primarily governed by the Regulation on the Operating Principles of Digital Banks and Service Model Banking (“Digital and Service Banking Regulation”). This regulation sets out rules on incorporation, operations, management and capital requirements for digital banks. Digital banks may carry out all activities permitted to credit institutions, depending on whether they are licensed as deposit or participation banks.

Digital banks may extend loans only to financial consumers and small and medium-sized enterprises (SMEs). However, digital banks are permitted to carry out transactions qualifying as loans under the Banking Law through their activities in interbank markets or money and capital markets, to extend loans to other banks, and to grant foreign currency loans to enterprises exceeding SME thresholds. Where a customer initially qualifies as an SME but later exceeds SME size limits, the digital bank may continue to provide only the services permitted for non-SME customers until the customer falls back within SME thresholds. Digital banks are required to establish at least one physical office to handle customer complaints and may provide services through their own or third-party ATMs.

1.2.2 Digital banking market in Türkiye

Türkiye’s first bank to operate without branches and entirely through digital channels is Hayat Finans, which obtained its operating licence in March 2023. The first digital public bank, as well as the first digital bank established under the majority ownership of an existing bank, is Ziraat Dinamik Banka A.Ş., an affiliate of T.C. Ziraat Bankası A.Ş., which obtained its operating licence in October 2024. According to the official website of the BRSA, there are currently five digital banks operating in Türkiye, three operating as deposit banks and two operating as participation banks. One of the largest players in the Turkish digital banking sector, Enpara Bank A.Ş., holds a conventional deposit bank licence rather than a digital banking licence, despite essentially operating as a digital bank in practice. In addition to fully digital banks, conventional banks in Türkiye are also actively engaged in digital banking activities.

According to the Banks Association of Türkiye’s Report on Digital, Internet and Mobile Banking Statistics, as of September 2025 there were 126,104 million active digital banking customers (individual and corporate), defined as users that had conducted transactions within the last three months. This represents an increase of 8,802 million customers compared with the previous year.

1.3 Service model banking

1.3.1 Regulatory framework

The procedures and principles governing BaaS are set out under the Digital and Service Banking Regulation. For a service to qualify as a BaaS, customers must access the banking services offered by the bank through the interface provided by an interface provider, and such access must be established via open banking services. The BRSA is authorised to determine the technical criteria applicable to open banking services.

There are no restrictions as to which banks may act as BaaS. However, banks may provide services only within the scope of their authorised activities; accordingly, a bank may not offer, through an interface provider, any banking service that it is not authorised to provide directly. Decisions relating to the banking services to be offered to customers, such as credit allocation decisions, must be taken by the BaaS, and the relevant transactions must be recorded on the balance sheet of the relevant BaaS.

The Digital and Service Banking Regulation further requires interface providers to be established as capital companies in Türkiye, and to operate a mobile application or internet platform capable of enabling the provision of banking services. Banks are not permitted to act as interface providers.

1.3.2 BaaS market in Türkiye

Getir Teknolojik Hizmetler A.Ş. (“GetirFinans”) is the first entity to carry out service model banking activities in Türkiye. Fibabanka A.Ş. announced via the Public Disclosure Platform (PDP) in August 2024 that it had obtained the necessary BRSA approvals to commence service model banking activities through the interface provided by GetirFinans. The GetirFinans interface enables users to access Fibabanka’s products and services, including account opening, credit cards, money transfers, investment services and loan transactions. Migros Ticaret A.Ş., one of Türkiye’s largest supermarket chains, announced via the PDP in January 2026 that the BRSA had approved the application for its subsidiary, Money Finansal Teknoloji Hizmetleri A.Ş., to provide banking services as a service model interface provider for Colendi Bank A.Ş. These recent developments signal a growing adoption of BaaS in Türkiye.

2. Payment and e-money institutions

2.1 Regulatory framework

Payment and e-money institutions operate under the Payment Services Law, introduced in June 2013, together with the Regulation on Payment Services, Electronic Money Issuance, Payment Institutions and Electronic Money Institutions (“Payment Services Regulation”), alongside applicable secondary legislation. Moreover, payment institutions and electronic money institutions, along with other financial entities such as banks, non-bank card issuers, financing and factoring companies and crypto-asset service providers, are classified as obligors under Turkish anti-money laundering legislation. Accordingly, they are subject to a broad range of obligations, including customer due diligence and know-your-customer (KYC) requirements, transaction monitoring, the establishment of internal compliance programmes, record-keeping and suspicious transaction reporting.

Pursuant to the amendments introduced to the Payment Services Law in January 2020, the authority to issue secondary legislation on payment services, as well as oversight powers including activity monitoring and the granting of operating licences, were transferred from the BRSA to the CBRT.

The Payment Services Law explicitly lists the activities that qualify as payment services. Such services may only be offered to persons residing in Türkiye by payment institutions licensed by the CBRT. The licence granted by the CBRT is activity-specific, meaning that payment institutions are authorised to provide only those payment services expressly specified in their licence, rather than holding a general authorisation covering all payment services regulated under the law.

In addition, the CBRT issued the Guideline on the Association of Business Models Offered in the Payments Field with Payment Service Types in September 2022. This Guideline aims to map business models commonly encountered in the payments sector to the payment services regulated under the Payment Services Law and to clarify the type of authorisation required for each service.

Accordingly, business models in the field of payment services include, among others:

• Operation of payment accounts, including the opening of payment accounts, cash deposits and cash withdrawals
• Money remittance services
• Virtual POS services
• Physical POS services
• Issuance and acceptance of electronic money, including prepaid cards
• Digital wallet services
• Mobile payment services
• Intermediation services for mobile payments

As per the amendment made to the Payment Services Regulation in October 2023, digital wallet activities have been introduced into Turkish legislation for the first time, which explicitly defines the digital wallet as a payment instrument that may be provided by payment service providers. Entities that were providing digital wallet services prior to the effective date of this amendment, and that could be classified as payment institutions or electronic money institutions under the Payment Services Law but did not hold an operating licence, were required to apply to the CBRT and obtain the necessary authorisations by the end of 2025.

2.2 Payment and e-money institutions market in Türkiye

Following the establishment of the regulatory framework, subsidiaries of incumbent banks as well as independent start-ups have begun to obtain licences to operate in the market, a process that is still ongoing. According to the most recent data published on the website of the CBRT, there are currently 63 electronic money institutions and 23 payment institutions operating in Türkiye.

3. Crowdfunding (peer-to-peer funding)

3.1 Regulatory framework

One of the fintech models that has gained increasing prominence as an alternative financing method is crowdfunding. In Türkiye, peer-to-peer funding transactions are conducted through crowdfunding platforms, which allows funding of projects and venture companies by collecting funds from the public.

Following the introduction of regulations on equity-based crowdfunding, the CMB issued Communiqué No. III-35/A.2 on Crowdfunding (“Crowdfunding Communiqué”) in October 2021, thereby providing a legal framework for both equity-based and debt-based crowdfunding models.

Crowdfunding platforms are required to fulfil the statutory requirements set out under the applicable legislation and obtain authorisation from the CMB.

The Crowdfunding Communiqué sets out detailed rules regarding, inter alia, the establishment of platforms, membership principles, investment limits, marketing and promotion activities, as well as the permitted and prohibited activities of platforms.

Platforms operating solely on an equity-based crowdfunding basis are prohibited from intermediating lending or similar activities in return for interest or any other consideration, including those involving the taking of pledges, and from conducting crowdfunding activities in return for any capital markets instrument other than shares.

Similarly, debt-based crowdfunding platforms are prohibited from carrying out activities that give rise to a debt relationship through any means other than the issuance and sale of debt instruments, or from engaging in crowdfunding activities in return for any capital markets instrument other than debt instruments.

Under the Crowdfunding Communiqué, platforms shall not engage in funding activities intended to collect funds from Turkish residents for the benefit of natural or legal persons resident abroad. Nevertheless, the participation of Turkish residents in crowdfunding activities conducted through foreign platforms is not subject to the provisions of the Crowdfunding Communiqué. However, where a foreign platform has established a workplace in Türkiye, operated a website in Türkiye, or conducted direct or indirect marketing or promotional activities aimed at persons resident in Türkiye, the provisions of the Crowdfunding Communiqué shall apply to such activities.

3.2 Crowdfunding market in Türkiye

The first crowdfunding platform of Türkiye, Vakıf Yatırım Menkul Değerler A.Ş., an affiliate of Türkiye Vakıflar Bankası T.A.O, was listed as a crowdfunding platform by the CMB in April 2021. As of 2026, there are 19 crowdfunding platforms operating in Türkiye. Notably, six new platforms have been established over the past two years, indicating growing momentum in the sector.

4. Crypto-assets

4.1 Regulatory framework

Among fintech models, one of the most recent and impactful developments has been the regulation of crypto-assets and crypto-asset service providers. The first regulation addressing crypto-assets under Turkish law was the Regulation on the Non-Use of Crypto-Assets in Payments issued by the CBRT in 2021. Pursuant to this regulation, crypto-assets cannot be used, either directly or indirectly, as a means of payment by individuals or entities operating in Türkiye. Moreover, payment service providers and electronic money institutions are prohibited from developing or offering business models that involve the direct or indirect use of crypto-assets in the provision of payment services or issuance of electronic money, and cannot act as intermediaries for funds transferred to or from platforms offering crypto-asset trading, custody, transfer or issuance services.

While this prohibition remains in force, the first comprehensive regulatory framework governing crypto-assets was introduced through an amendment to the Capital Markets Law No. 6362, which entered into force in July 2024.

Through this long-awaited amendment in the law, various issues such as the nature of crypto-assets, trading platforms, issuance of capital market instruments as crypto-assets, and the activities and liability regimes of service providers have been addressed under Turkish law. The main clarifications introduced by this amendment may be summarised as follows:

• It is accepted that crypto-assets may provide rights similar to capital market instruments but are not considered capital market instruments.
• Trading services and custody services are defined as two separate types of services.
• The CMB is designated as the regulatory authority for crypto-asset service providers, and the principles applicable to service providers and platforms are to be determined by the CMB.
• Entities operating as crypto-asset service providers are required to obtain a licence from the CMB.

Following the enactment of the amendment, a principle decision issued by the CMB in August 2024 introduced initial rules regarding the establishment of platforms, including requirements relating to their shareholders, management and capital structure. This was followed by a further principle decision issued in September 2024, which introduced restrictions relating to customer accounts, order-taking processes, and advertising and promotional campaigns, with a view to protecting investors and mitigating risks in the sector. In addition, certain issues to be considered by market participants during the transition period were highlighted.

In December 2024, amendments were introduced into the legislation of the Financial Crimes Investigation Board (MASAK) with regard to the classification of crypto-asset service providers as “financial institutions”, required sender and recipient information in crypto-asset transfers, and the obligations imposed on crypto-asset service providers such as compliance programmes, e-notifications, KYC and remote identification requirements.

Subsequently, the long-awaited secondary legislation was introduced in March 2025 through the CMB’s Communiqué No. III-35/B.1 on the Establishment and Operating Principles of Crypto-Asset Service Providers and Communiqué No. III-35/B.2 on the Operating Procedures and Principles and Capital Adequacy of Crypto-Asset Service Providers. With the entry into force of these communiqués, a comprehensive secondary regulatory framework governing crypto-assets has been established, while a transition period has been granted to crypto-asset service providers, including deferred effective dates for certain provisions.

4.2 Crypto-assets market in Türkiye

In accordance with the CMB’s announcement in July 2024, the “List of Operating Platforms” and the “List of Platforms Declaring Liquidation” were published on the CMB’s website. Pursuant to the transitional provisions set out in the above-mentioned regulations, the establishment and licensing processes for platforms and other crypto-asset service providers are being implemented on a phased basis and remain ongoing.

Although the application and authorisation processes are ongoing, as of January 2026, 58 companies are listed on the CMB’s official website under the “List of Operating Platforms” as operating as crypto-asset service providers and are continuing their activities until the required CMB licences are obtained.

These regulations and the related licensing process have led to significant developments in relation to crypto-assets. Nevertheless, the current regulatory framework primarily focuses on crypto-asset service providers, consumer protection and compliance issues, while remaining silent on certain areas, such as the issuance of capital market instruments in the form of crypto-assets which may be subject to future legislative or regulatory action.

Conclusion

The Turkish fintech sector continues to evolve at a rapid pace, as regulatory frameworks across digital banking and service banking, payment services, crowdfunding and crypto-assets become more established, and licensing and authorisation processes for market participants continue to progress. Alongside these regulatory developments, traditional financial institutions and market infrastructure providers are increasingly experimenting with blockchain-based initiatives, such as digital gold platforms, CBRT digital Turkish lira pilots, distributed ledger-based KYC systems and blockchain-enabled bond issuances outside Türkiye. Taken together with growing investment activity, broader market participation and an increasingly clear regulatory environment, these developments suggest that the Turkish fintech ecosystem is well placed to sustain further growth and innovation in the years ahead.

Originally published in Chambers