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Legal Alerts

Turkish Payment Services, E-Money and Open Banking Reform

Legal Alerts
Banking & Finance
IT & Communications

Recent Developments

The Draft Law on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions (the “Payment Services and Electronic Money Law“) and Amendments to Certain Laws (the “Draft Law“) was submitted to the Presidency of the Grand National Assembly of Turkey on October 17, 2019 and proposes to reform payment services and open banking in Turkey.

What’s New?

  • In accordance with the Draft Law, open banking products of payment initiation service providers (PISP) and account information service providers (AISP) will be defined as payment services and be included in the scope of payment services. Payment service providers will be entitled to provide these services as well. The Central Bank of the Republic of Turkey (the “CBRT“) will be authorized to supervise these services.
  • The Draft Law brings major changes to the regulation and supervision of payment service providers and e-money issuers. Within the scope of the Draft Law, the CBRT will be authorized to regulate and supervise these institutions in lieu of the Banking Regulatory and Supervisory Authority (the “BRSA“). The CBRT’s will also be entitled to supervise the third parties providing services to these institutions.
  • The CBRT will be entitled set the maximum limits of fees and commissions payable for payment services as part of its regulatory authority.
  • Within the scope of the prevailing legislation, services which are not currently defined as payment services will be included in the category of payment services if they reach the limits to be set by CBRT.
  • Pursuant to the Draft Law, if transactions used with closed loop payment instruments reach certain limits, they may become subject to the Payment Services and Electronic Money Law.
  • The Draft Law enables the CBRT to be a shareholder of the systemically important payment system operators (ödeme sistemi işleticisi) in order to maintain continuity of payment services.
  • The Draft Law transfers the BRSA’s duty to regulate and supervise set off and settlement (takas ve mahsup) transactions to the CBRT.
  • Within the scope of the Draft Law, the Payment and E-Money Institutions Association of Turkey will be established. Simultaneously, payment and e-money institutions will be subject to independent audit.
  • In addition, the Draft Law will increase in the administrative fines imposed under the Payment Services and Electronic Money Law.


In accordance with the Draft Law, important steps will be taken in payment services and open banking.

The Draft Law is the second and most important step in terms of regulating open banking in Turkey. The BRSA had taken the first step by introducing the Draft IT Systems Regulation to public review in 2018.

The Draft Law is expected to enter into force as of January 1, 2020. The institutions currently providing the foregoing open banking services and not authorized as a payment service provider will need to apply to the CBRT to obtain such authorization within one year of the entry into force of the Draft Law.