1.  How is crypto regulated?
  2. How quick and easy is to get a MiCA licence in Turkiye? 
  3.  Are the following activities regulated or unregulated in your jurisdiction? ― Direct sales of tokens by issuers — Exchange (buy/sell) ― Custody (hold) ― Borrowing/lending ― Yield/staking services ― Staking on proof of stake consensus mechanisms (please indicate if NFTs are treated differently from fungible cryptoassets for each activity)
  4. Can offshore business provide services to local customers on either active solicitation or reverse solicitation basis? 
  5. How long would establishing a cryptoasset business/obtaining a license in your jurisdiction take?
  6. What would be the approximate overall cost of obtaining a licence?
  7. What is the probability (%) of success in obtaining a licence?
  8. What other limitations are there in your jurisdiction when looking to set up a cryptoasset business? E.g., Compliance requirements and physical presence

jurisdiction

Turkiye

Disclaimer: This chapter was last updated on 20 June 2025 and does not reflect any subsequent developments. The information provided is intended for general informational purposes and should not be construed as legal advice.

1. How is crypto regulated?

AML RegulationAny other regulation

As of 2021, crypto-asset service providers defined as service providers that intermediate the trading of cryptoassets through electronic trading platforms under the AML legislation, are designated as obligors. As such, they are required to comply with specific requirements mandated by the AML legislation.

In December 2024, significant amendments were made to the AML legislation, enhancing the measures and requirements for cryptoasset service providers. These amendments include:

  1. Classifying cryptoasset service providers as financial institutions, which tightens the required measures to prevent money laundering and financing of terrorism. However, at the same time, this classification provides certain opportunities, such as facilitating customer acquisition through the “trust in a third party” principle.
  2. Mandating the establishment of a compliance program to ensure adherence to AML requirements, which includes appointing compliance officers and deputy compliance officers.
  3. Introducing requirements for cryptoasset transfer messages to include detailed information, taking into consideration the "Travel Rule", alongside enhanced KYC obligations.
  4. Requiring registration with the Financial Crimes Investigation Board's Electronic Notification System to ensure secure regulatory communication.

Please refer to the responses to question 8 for further details regarding the December 2024 amendments.

Amendments regulating crypto were incorporated into the Capital Markets Law and entered into force on 2 July 2024 ("the Law").

The Law sets out detailed rules for the operation of crypto-asset service providers, permitted crypto-asset transactions, and the transitional period for the status of existing platforms, as it introduces a licensing requirement along with new liabilities.

Issues not addressed in the Law are regulated by secondary legislation, which includes Communiqués issued by the Capital Markets Board (CMB) on establishment, operational procedures, and capital adequacy principles, as well as CMB resolutions.

The secondary legislation provides comprehensive regulation of crypto-asset service providers, addressing areas such as establishment and licensing procedures, share transfers, participation restrictions, and outsourcing arrangements. It also sets out requirements concerning capital adequacy, personnel qualifications, and the scope of permitted activities. In addition, the legislation outlines principles for internal control, risk management, internal audit, and information systems audits, as well as rules governing custody services for crypto-assets and operational conduct standards.

Licensing Requirement

Crypto-asset service providers in operation as of the Law's entry into force were required to notify the CMB, confirming that they would either:

  • Commit to applying for a license by meeting the requirements outlined in the secondary legislation under the Law Amendment; or
  • Resolve to liquidate within three months, ensuring no losses to clients and refraining from onboarding new clients during this period.

Crypto-asset service providers that have either successfully applied for a licence or for establishment with the CMB must apply for an operating permit by 30 June 2025. After submitting the operating permit application, these entities are required to meet the conditions set forth under the legislation and must obtain their licences by 30 June 2026.

2. How quick and easy is to get a MiCA licence in Turkiye? 

N/A

3. Are the following activities regulated or unregulated in your jurisdiction? ― Direct sales of tokens by issuers — Exchange (buy/sell) ― Custody (hold) ― Borrowing/lending ― Yield/staking services ― Staking on proof of stake consensus mechanisms (please indicate if NFTs are treated differently from fungible cryptoassets for each activity)

AML RegulationAny other regulation
These activities are not specifically regulated under the AML regulations. However, the AML legislation broadly defines cryptoasset service providers as service providers that intermediate the trading of cryptoassets through electronic trading platforms.

Direct sales of tokens by issuers

Direct sales of certain tokens, such as security tokens, fall within the scope of the Law. Crypto-asset service providers involved in these activities must obtain a license from the CMB.

Exchange (buy/sell)

The Law applies same regulations for exchanges (buy/sell) as for direct sales. Crypto-asset service providers engaged in this activity must also obtain a license from the CMB.

Custody (hold)

Crypto-asset service providers offering custody services must obtain a license from the CMB.

Borrowing/lending

The CMB Resolution dated 19 September 2024 and CMB Communiques prohibit platforms from engaging in lending transactions, providing credit to customers, and offering leveraged transactions.

Yield/staking services

Currently, there is no explicit regulation governing yield or staking services.

Staking on proof-of-stake consensus mechanism

This activity is also not explicitly regulated.

NFTs

According to the CMB Resolution dated 19 September 2024, activities related to NFTs, including buy/sell, first sale or distribution, exchange, transfer, and custody, are outside the scope of the Law. Entities exclusively engaged in such activities are therefore not subject to the Law. However, if a crypto-asset service provider carries out NFT-related activities in addition to its other regulated services, it is required to notify the CMB that it is offering such services. It remains unclear whether other laws or regulatory bodies other than CMB will regulate these activities in detail in the future. 

4. Can offshore business provide services to local customers on either active solicitation or reverse solicitation basis? 

AML RegulationAny other regulation
N/A. 

Crypto-asset platforms based abroad may offer services to individuals residing in Türkiye, provided they refrain from conducting any promotional, advertising, or marketing activities targeting such individuals. These services must be initiated solely at the discretion of the individuals residing in Türkiye. Within this framework, crypto-asset platforms based abroad may provide cryptocurrency services in Türkiye without obtaining a local license.

However, engaging in activities directed at residents in Türkiye by crypto-asset platforms based abroad is considered unauthorised crypto-asset service provision. Establishing a website in Turkish language, conducting promotional and marketing activities related to the services directed at residents in Türkiye and establishing a workplace in Türkiye are considered activities directed at residents in Türkiye.

5. How long would establishing a cryptoasset business/obtaining a license in your jurisdiction take?

AML RegulationAny other regulation
N/A.As of 20 June 2025, no crypto-asset service provider has been listed by the CMB as having obtained a licence, and compliance efforts by these providers are still ongoing. However, the legislation requires that all crypto-asset service providers apply for an operating permit obtain their licences by 30 June 2026.

6. What would be the approximate overall cost of obtaining a licence?

AML RegulationAny other regulation
N/A.

The regulations do not specify the cost of obtaining a licence directly. However, crypto-asset platforms must have a minimum paid-up capital of TRY 50 million in cash, which the platform’s equity cannot fall below. Additionally, crypto-asset trading platforms must pay an annual fee of 1% of their total income, excluding interest income, to both the Capital Markets Board (CMB) and the Scientific and Technological Research Council of Türkiye (TUBITAK), making for a total fee of 2% per year. 

These requirements indicate significant financial commitments for any crypto-asset service provider aiming to operate under the new regulations.

7. What is the probability (%) of success in obtaining a licence?

N/A.

8. What other limitations are there in your jurisdiction when looking to set up a cryptoasset business? E.g., Compliance requirements and physical presence

AML RegulationAny other regulation

The December 2024 amendments to the AML legislation impose further obligations on cryptoasset service providers to enhance transparency and accountability. The following sections provide detailed insights into certain obligations of cryptoasset service providers under AML legislation:

  • Financial Institution Status

Financial institutions, such as banks, insurers, and portfolio management firms, are subject to extended obligations and certain opportunities under the AML legislation, compared to obligors, which encompass financial institutions as a subset. With the December 2024 amendments, cryptoasset service providers are now classified as financial institutions. Consequently, regulations that already apply to financial institutions are now extended to include cryptoasset service providers. These regulations involve taking measures against technological risks, utilizing the third-party principle (acting based on measures taken by another financial institution), and managing relationships with high-risk countries.

  • KYC Procedures

Cryptoasset service providers must identify customers in the following scenarios:

  1. Establishing a continuous business relationship, regardless of the transaction amount.
  2. Carrying out transactions whose amount, or the total amount of more than one interconnected transaction, exceeds TRY 15,000.
  3. Conducting electronic transfers and crypto-asset transfers when the transaction amount or the total amount of more than one interconnected transaction exceeds TRY 15,000.
  4. When there are suspicious transactions or doubts regarding previously obtained customer information, irrespective of transaction size.

Effective from 25 February 2025, cryptoasset service providers must include the following information in cryptoasset transfer messages for transactions of TRY 15,000 or more.

  1. Name/title/trade name of individuals and entities.
  2. Wallet address of the sender, or a transaction reference number in the absence of a wallet address.
  3. At least one identifying detail, such as address, customer number, ID number, tax ID number, passport number, or other unique identifiers.

The accuracy of these details must be verified before the transaction is processed. For recipients, information under (i) and (ii) must be included in the transfer message; however, verification of recipient details is not mandatory.

For transactions below TRY 15,000, transfer messages must still include the information under (i) and (ii) for both sender and recipient, but no verification obligation applies.

All cryptoasset service providers intermediating the transfer must include the required information for sender in the transfer messages.

If a transfer message lacks the required information, the receiving cryptoasset service providers must request the missing details from the sender cryptoasset service providers. If the information is not provided, the receiving cryptoasset service providers are obligated to return the transfer. In cases of repeated non-compliance, the receiving cryptoasset service providers should consider rejecting further transfers from the sender cryptoasset service providers or terminating the business relationship altogether.

In cross-border transfers involving foreign cryptoasset service providers or financial institutions that are not required by their own legislation to share information about the sender and the recipient, the service provider shall obtain from the customer involved in the transfer a declaration regarding at least one piece of information that can be used to identify the sender or the recipient.

  • Compliance Program

Cryptoasset service providers must implement a compliance program designed to address risks associated with money laundering and financing of terrorism. The program must be operational within one month of appointing a compliance officer. The deadline for the appointment of a compliance officer, who will oversee the implementation and operation of the program is set for 25 January 2025.

The compliance program must include a comprehensive set of internal policies and procedures tailored to the specific risks cryptoasset service providers face. These policies should cover risk assessment, management, and mitigation strategies. Cryptoasset service providers must establish mechanisms for monitoring transactions, identifying suspicious activities, and reporting them to the Financial Crimes Investigation Board. Additionally, they must integrate measures for freezing assets and monitoring customer transactions.

Certain limitations are imposed on payment service providers and payment and electronic money institutions under the Regulation on the Disuse of Crypto-assets in Payments. Accordingly:

  • payment service providers cannot develop business models that involve the direct or indirect use of crypto-assets in the provision of payment services and the issuance of electronic money, nor can they offer any services related to such business models, and
  • payment and electronic money institutions are prohibited from acting as intermediaries for platforms that offer trading, custody, transfer, or issuance services for crypto-assets, or for fund transfers made from these platforms.

The Law and its secondary legislation

Some of the key provisions of the Law and its secondary legislation are listed below.

  • Crypto-asset service providers must apply to the Turkish Capital Markets Association to become members within three months after obtaining their certificates. The activities of crypto-asset service providers that fail to fulfil this membership obligation will be ceased by the CMB.
  • The Law sets forth requirements for the shareholders, directors, representatives of the crypto-asset service providers.
  • The articles of association of crypto-asset service providers must stipulate that their activities are limited to crypto-asset trading, initial sale or distribution, custody, etc.
  • The phrase “crypto-asset trading platform” should be included in the trade names of crypto-asset service providers to indicate the services they will offer.
  • The shareholding structure should be transparent and open.
  • Share transfers exceeding certain thresholds or involving privileged shares must receive prior approval from the CMB to be valid. Transfers below the threshold must be notified to the CMB within 10 days of completion.
  • Crypto-asset service providers are allowed to invest without any limit in financial institutions such as capital market institutions, exchanges, precious metal intermediary institutions, insurance companies, private pension companies, financial leasing, factoring, financing, savings financing, and asset management companies, and other financial institutions approved by CMB. However, they are not allowed to invest in:
    • Companies where they own more than 10% of the paid-in capital, or
    • Companies where their managers, individually or together, hold more than 25% of the capital.

Additionally:

Their total investments in companies outside the permitted categories listed above cannot exceed 25% of their equity.

  • If crypto-asset service providers fail to meet their transfer obligations or if their financial structure weakens, the CBM can take various measures, up to and including the withdrawal of the licences of crypto-asset service providers.
  • In response to certain unauthorized activities on the Internet, the CMB may decide to block access to the offending site or to remove the content.
  • Investment advisory services may only be offered to customers whose current value of crypto-assets on the relevant platform is at least TRY 50,000,000.

Individuals and individual representatives of entities who conduct unauthorized crypto-asset service activities will be subject to imprisonment for three to five years and a judicial fine ranging between TRY 500,000 to TRY 5,000,000.