New regulatory regime for insurance support services in Türkiye

The Regulation Amending the Regulation on Insurance Support Services (the “Regulation”), published by Türkiye’s Insurance and Private Pension Regulation and Supervision Agency (the “IPRSA”) and entered into force on 23 July 2026, introduces a new authorisation and regulatory regime for insurance support service providers operating particularly in the fields of claims management, 24/7 assistance services and claims investigation.

The Regulation has made claims management and 24/7 assistance services, as well as claims investigation activities, subject to the authorisation of the IPRSA and introduced new requirements concerning corporate form, financial adequacy, shareholding structure and professional qualifications applicable to natural and legal persons engaged in such activities.

Support services subject to the IPRSA authorisation

Under the new amendments, the authorisation of the IPRSA is required for two categories of service providers: (i) claims management service providers that supply insurers with the full range of services comprising the receipt of claim notifications, the opening of claim files in the insurer’s system, the request for information and documents from claimants, and the assessment of claims; and (ii) assistance service providers offering emergency assistance, roadside assistance, and home or workplace assistance on a 24/7 basis upon the occurrence of an insured event.

Insurance support services falling outside the specific authorisation regime will continue to be subject to the general registration and operating requirements.

New requirements for claims management and assistance service providers

Service providers wishing to provide the services falling within the scope of the authorisation must have their registered headquarters in Türkiye and be incorporated as a joint stock company. They must also have adequate premises, technical and systems infrastructure, administrative organisation and human resources for the conduct of their activities.

The minimum equity requirement for these service providers has been set at TRY 250 million (approx. EUR 4.6m). The IPRSA is authorised to reduce this amount by up to half or increase it by up to twofold, taking into account the volume and nature of the business conducted with insurers. Unless otherwise determined by the IPRSA, this amount will be updated annually at the beginning of each calendar year by the domestic producer price index rate announced by the Turkish Statistical Institute. The founders must not be bankrupt or subject to insolvency proceedings (konkordato), must have the financial standing and reputation required to act as a founder or shareholder and must not have been convicted of the offences specified under the Insurance Law No. 5684. Shareholders directly or indirectly holding at least 10% of the capital, voting rights or usufruct rights, as well as holders of privileged shares enabling them to exercise influence over management despite holding an interest below this threshold, must also satisfy the eligibility requirements applicable to founders.

Before commencing the provision of services, these service providers must first obtain authorisation from the IPRSA and subsequently register in the list maintained by the Insurance Information and Monitoring Centre. If the conditions underlying the authorisation are subsequently no longer satisfied, or if breaches of the applicable legislation are not remedied within the period granted by the IPRSA, the service provider’s activities may be temporarily suspended, or its authorisation may be revoked.

In addition, direct or indirect share transfers resulting in the acquisition or crossing of the 10%, 33% or 50% thresholds in the service provider’s capital, or causing a shareholding to fall below any of these thresholds, will be subject to the prior approval of the IPRSA.

New regime for claims investigators

Claims investigation activities conducted by persons other than employees of an insurer will also be subject to the authorisation of the IPRSA. Natural person claims investigators must be resident in Türkiye, have graduated from a higher education programme of at least two years, have at least two years’ experience in claims-related operations in the insurance sector and successfully complete the training provided by the Insurance Training Centre.

Legal entity claims investigators will be required to have their registered headquarters in Türkiye, and their authorised representatives and shareholders must satisfy the financial standing and criminal-record requirements set out in the Regulation. In addition, the persons authorised to represent and bind the legal entity in relation to claims investigation activities must themselves be natural person claims investigators authorised by the IPRSA.

Claims investigators must base their assessments on concrete information and documents. The authorisation of a claims investigator may be revoked if it is established that the investigator failed to conduct the necessary examination and investigation, deliberately reached a biased conclusion or adopted an accusatory attitude or conduct towards the relevant parties.

Separation of activities and conflicts of interest

The Regulation further clarifies the separation between support services and insurance intermediation activities. Natural and legal persons providing support services may not engage in insurance intermediation activities, while natural and legal persons carrying out insurance intermediation activities may not provide support services.

The restrictions applicable to persons serving on the management or supervisory bodies of insurers, insurance intermediaries and loss adjusters, as well as persons authorised to sign on their behalf, have also been expanded in respect of their managerial, shareholding, employment and fee-based business relationships with support service providers.

Transition period for existing providers

The Regulation introduces a phased transition period for the existing providers that are already operating. Existing providers falling within the scope will be required to comply with the new provisions, other than the requirement to be incorporated as a joint stock company and minimum equity requirements, by 31 December 2026. The deadline for complying with the requirement to be incorporated as a joint stock company is 31 December 2028. Existing providers must increase their equity to at least 25% of the prescribed minimum amount by 31 December 2026, at least 50% by 31 December 2028 and the full amount by 31 December 2030.

Existing claims investigators must comply with the new requirements by 31 December 2026. Claims investigators who can demonstrate that they provided claims investigation services to insurers during the preceding year will be exempt from the higher education requirement.

The IPRSA is authorised to extend the periods specified in the Regulation by up to six months.

In this context, existing service providers and claims investigators falling within the scope of the new authorisation regime will be required to comply with the applicable requirements within the timeframes set out in the transitional provisions and to complete the authorisation process with the IPRSA.