Crypto

The Regulatory Framework for Crypto Platforms in Turkey

Crypto platforms in Turkey are regulated by the Capital Markets Board (CMB/SPK) under Capital Markets Law No. 6362 as amended by Law No. 7518 of 2 July 2024. Any platform that trades, holds in custody or transfers crypto assets for Turkish users now needs a CMB licence, must meet large minimum-capital thresholds, and must comply with anti-money-laundering rules enforced by MASAK. This guide explains the framework, the licensing path and what it means for foreign investors, operators and users.

From grey zone to licensed market

For years, crypto trading in Turkey operated without a dedicated legal framework. Platforms could be set up under ordinary company law, and the only binding rules came from anti-money-laundering legislation and a single payments restriction. That changed decisively with Law No. 7518, published in the Official Gazette on 2 July 2024, which amended the Capital Markets Law No. 6362 (Sermaye Piyasası Kanunu) to create a complete licensing regime for crypto asset service providers.

The reform did two things at once. It defined crypto assets and crypto asset service providers (CASPs) as regulated concepts, and it placed them under the supervisory authority of the Capital Markets Board (Sermaye Piyasası Kurulu, or CMB/SPK). Operating a crypto platform in Turkey is no longer a matter of ordinary commercial freedom; it requires a permit from a financial regulator. For the wider picture, see our overview of Turkey's crypto asset regulatory landscape.

The law: The framework sits in Capital Markets Law No. 6362, amended by Law No. 7518 (Official Gazette, 2 July 2024). The detail comes from two CMB communiqués, III-35/B.1 and III-35/B.2, both published in the Official Gazette on 13 March 2025 (No. 32840).

Who regulates crypto platforms in Turkey

Three authorities matter for anyone running or using a crypto platform in Turkey, and their roles overlap rather than replace each other.

Capital Markets Board (CMB / SPK)

Since Law No. 7518, the CMB is the primary regulator. It licenses CASPs, sets their operating principles and capital requirements, supervises their conduct, and can suspend or revoke authorisation. A platform that issues, trades, holds in custody, transfers or otherwise provides services in crypto assets falls within its remit.

MASAK (Financial Crimes Investigation Board)

Crypto exchanges have been classified as obliged parties (yükümlü) under anti-money-laundering rules since 2021. Under Law No. 5549 on the Prevention of Laundering Proceeds of Crime, platforms must apply customer identification (KYC), monitor transactions, keep records and file suspicious transaction reports to MASAK (Mali Suçları Araştırma Kurulu). These duties continue alongside the new CMB licensing system.

Central Bank (TCMB)

The Central Bank issued the 2021 regulation that prohibits the use of crypto assets as a means of payment, directly or indirectly. The Regulation on the Disuse of Crypto Assets in Payments was published in the Official Gazette on 16 April 2021 (No. 31456) and took effect on 30 April 2021. Crypto can be bought, sold and held as an asset, but it cannot be used to settle payments for goods and services, and payment service providers may not build business models around crypto payments.

What counts as a crypto asset service provider

Law No. 7518 defines a crypto asset broadly as an intangible asset that can be created and stored in electronic form using distributed ledger or similar technology, distributed over networks, and that expresses value or rights. A crypto asset service provider is any entity that provides services connected to those assets.

In practice the regime captures several distinct business models, each with its own obligations:

  • Crypto asset trading platforms (exchanges) that match buyers and sellers or trade against their own book.
  • Custody institutions that hold crypto assets or the keys to them on behalf of customers.
  • Wallet and transfer service providers that move assets between addresses for clients.

One structural point matters before anything else: a CASP must be incorporated in Turkey as a joint-stock company (anonim şirket) with fully paid-in capital. Foreign founders usually begin by helping a Turkish entity set up a Turkish joint-stock company to hold the licence.

The reach over foreign platforms and offshore activity

Foreign-incorporated platforms cannot escape the rules simply by serving Turkish residents from abroad. The framework is designed to reach services directed at the Turkish market, so a business actively targeting Turkish users should assume it needs Turkish authorisation.

In practice, the line is drawn around active solicitation. A platform that markets in Turkish, advertises to Turkish residents, offers Turkish-lira on-ramps or otherwise courts Turkish customers is treated as operating in Turkey and needs a CMB licence. Authorities can also restrict access to non-compliant foreign sites. A purely passive relationship, where a Turkish resident independently approaches an offshore platform without being solicited, sits closer to the edge of the rules, but the safe assumption for any operator with a Turkish customer base is that the regime applies.

Watch the exposure: Operating or soliciting Turkish users without a CMB licence is no longer a grey area. Unauthorised crypto asset activity can trigger administrative sanctions under the Capital Markets Law and, where the conduct involves unlicensed financial services or deception, criminal exposure. Confirm your position before marketing to Turkish residents.

Licensing, capital and the secondary regulations

Law No. 7518 set the framework; the detail arrived through two CMB communiqués published in the Official Gazette on 13 March 2025 (No. 32840):

  • Communiqué III-35/B.1 on the establishment and operating principles of CASPs; and
  • Communiqué III-35/B.2 on operating procedures, capital adequacy and custody.

The single most important practical change is capital. CASPs must be joint-stock companies with fully paid-in capital, and the minimum thresholds are high:

The law: Under Communiqué III-35/B.2, minimum share capital is TRY 150,000,000 for crypto asset platforms and exchanges, and TRY 500,000,000 for crypto asset custody institutions. A custody institution holding more than TRY 1 billion in client assets must hold additional equity equal to 1.5% of the excess above TRY 1 billion.
ActivityLicence requiredMinimum share capitalKey obligation
Trading platform / exchangeCMB authorisationTRY 150,000,000Order matching, market conduct, customer protection
Custody institutionCMB authorisationTRY 500,000,000Segregation and safekeeping of client crypto assets
Wallet / transfer serviceCMB authorisationSet by activity scopeAML, travel-rule data and transfer controls

Other core features of the licensing regime include:

  • Mandatory CMB authorisation before a platform may operate or continue operating in Turkey.
  • Fit-and-proper standards for founders, shareholders and managers.
  • Governance, internal control and information-security obligations, reflecting the technical risk of holding digital assets.
  • Customer asset segregation, so that client crypto holdings are kept separate from the platform's own assets and protected if the operator fails.

If you are structuring or acquiring a licensed platform, the capital threshold, fit-and-proper review and market consolidation all shape the deal, so the structuring work should start before any application.

The transition deadlines you cannot miss

A transition regime applies to platforms that were already operating when the rules took effect. It runs on two hard dates:

  • Apply for an operating licence by 30 June 2025. Existing operators (and custody institutions on the CMB's list of operating entities as at 13 March 2025) had to file their application by this date.
  • Obtain the licence by 30 June 2026. Applicants must satisfy the CMB's operating conditions and hold an authorisation certificate by this final date.

An operator that fails to apply by 30 June 2025, or fails to obtain its licence by 30 June 2026, becomes subject to the liquidation provisions in Communiqué III-35/B.1. Out of the many platforms that previously operated informally, only a limited number entered the transition process, signalling a sharp consolidation of the market toward licensed operators.

Watch the deadline: The 30 June 2026 deadline to hold a CMB licence is imminent. An operator still serving Turkish users without an authorisation certificate after that date faces liquidation provisions. If your application is outstanding, treat this as urgent and take Turkish legal advice now.

Compliance obligations for operators

A licensed platform carries continuing obligations that go well beyond the initial permit. The most important fall into four groups.

Anti-money-laundering and KYC

Under Law No. 5549 and MASAK secondary legislation, platforms must verify customer identity, apply enhanced due diligence to higher-risk clients, monitor and record transactions, and report suspicious activity. Travel-rule information sharing on transfers and sanctions screening are expected. Newer AML measures also include withdrawal holds (commonly 48 hours, and longer for a first withdrawal from an account) and limits on stablecoin transfers, with stricter limits for platforms that do not apply the travel rule.

Tip: Build your withdrawal-hold, transfer-limit and travel-rule logic into the product from day one. These AML controls are operational, not just policy on paper, and the CMB and MASAK expect them to function in the live system.

Custody and client asset protection

Client crypto must be held under the custody rules in Communiqué III-35/B.2, with segregation designed so that customer holdings are not part of the platform's own estate. For anxious users, this bankruptcy-remoteness of client assets is the single most reassuring feature of dealing with a licensed operator rather than an informal one.

Consumer and market-conduct rules

As CMB-supervised entities, platforms must treat customers fairly, disclose risks, handle complaints and avoid market abuse. Misleading promotion of crypto products can expose operators to regulatory and civil liability under the Capital Markets Law and, where deception is involved, to criminal exposure under the Turkish Penal Code (Law No. 5237). Clear, compliant customer terms and platform agreements are part of meeting these duties.

Data protection and information security

Handling Turkish users' personal data triggers obligations under the Personal Data Protection Law (KVKK, Law No. 6698), including registration where required and breach notification. The CMB's information-systems rules add specific cybersecurity and resilience requirements.

How crypto gains are taxed in Turkey

As of mid-2026, Turkey has no crypto-specific gains or transaction tax in force. Crypto gains are dealt with under the general income and corporate tax framework, and the treatment of an individual's gains can depend on the facts. This is an area to confirm with a Turkish tax adviser rather than assume.

There was a notable development worth knowing about. On 2 March 2026 the ruling party submitted an omnibus bill proposing a 10% withholding tax on crypto gains (withheld quarterly through platforms) and a 0.03% transaction levy on service providers. Those crypto tax articles were withdrawn from the bill on 26 March 2026 after parliamentary negotiations, so they did not become law. The government has signalled it may bring back a refined version in a later proposal, so the position should be re-checked before you rely on it.

Tip: Do not price a Turkish crypto venture or a personal exit on the assumption that gains are tax-free indefinitely. Take specific Turkish tax advice and revisit it whenever a new bill is tabled.

What this means for foreign investors and users

For foreign investors and founders, the message is that Turkey now has a real, EU-influenced regulatory framework. That brings legitimacy and bank access for compliant operators, but it also means substantial upfront capital, licensing time and ongoing compliance cost. Entering the market without authorisation is no longer viable, and the high capital thresholds favour well-funded entrants and consolidation.

For foreign users and expats, trading and holding crypto remains lawful, but using it to pay for goods and services in Turkey is prohibited. Choosing a CMB-licensed platform is the safest route, because licensed operators are subject to customer-protection and asset-segregation rules. If a platform fails or withholds your assets, a Turkish lawyer can advise on enforcing claims against an insolvent platform.

Tip: This article is a general overview and is not legal advice. Crypto regulation in Turkey is moving quickly through communiqués and Board decisions. Confirm the current position with a Turkish lawyer before acting. Contact our team to map the rules to your platform or transaction.

Frequently asked questions

Is it legal to operate a crypto exchange in Turkey?

Yes, but only with authorisation from the Capital Markets Board (CMB/SPK). Since Law No. 7518 came into force in July 2024, crypto asset service providers must be licensed and must meet capital, governance and information-security requirements. Operating without a licence can lead to administrative sanctions and, in some cases, criminal exposure.

How much capital do you need to license a crypto exchange in Turkey?

Under Communiqué III-35/B.2, the minimum share capital is TRY 150,000,000 for a crypto asset platform or exchange and TRY 500,000,000 for a crypto asset custody institution. The provider must be a Turkish joint-stock company with fully paid-in capital. Custody institutions holding over TRY 1 billion in client assets must hold extra equity equal to 1.5% of the excess.

What are the deadlines for a crypto licence in Turkey?

Existing operators had to apply for a CMB operating licence by 30 June 2025 and must obtain the licence by 30 June 2026. A platform that misses these dates becomes subject to the liquidation provisions in Communiqué III-35/B.1. As of mid-2026 the final deadline is imminent, so outstanding applications should be treated as urgent.

Can I use cryptocurrency to pay for things in Turkey?

No. A 2021 Central Bank regulation (Official Gazette, 16 April 2021) prohibits using crypto assets as a means of payment, directly or indirectly. You may legally buy, sell and hold crypto as an asset, but you cannot use it to settle payments for goods and services in Turkey.

Is there a crypto tax in Turkey?

As of mid-2026 there is no crypto-specific gains or transaction tax in force. Crypto gains fall under general income and corporate tax rules. A March 2026 proposal for a 10% gains withholding and a 0.03% transaction levy was submitted to parliament and then withdrawn, so it is not law. Take Turkish tax advice and re-check the position regularly.

Do foreign crypto platforms need a Turkish licence to serve Turkish users?

A platform actively targeting Turkish residents, for example by marketing in Turkish or offering Turkish-lira on-ramps, should assume it needs CMB authorisation. The framework is intended to reach services directed at the Turkish market, and access to non-compliant foreign sites can be restricted. Take specific legal advice on your structure.

Which laws govern crypto platforms in Turkey?

The core framework is Capital Markets Law No. 6362 as amended by Law No. 7518, with CMB Communiqués III-35/B.1 and III-35/B.2 (Official Gazette, 13 March 2025). Anti-money-laundering duties come from Law No. 5549 (MASAK), data protection from Law No. 6698 (KVKK), and a Central Bank regulation governs the payment ban.

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