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Legal Alerts

A New Era for Payment Services and E-Money: Interest Bearing Funds

Legal Alerts
Banking & Finance
Financial Institutions

Recent Developments

The Regulation Amending the Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers (the “Amending Regulation“), which was prepared by the Central Bank of the Republic of Türkiye (the “CBRT“) and contains significant amendments to the Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers (the “Regulation“), was published in the Official Gazette on March 19, 2026. You can access the Amending Regulation here.

What Does the Amending Regulation Bring?

Funds Collected Within the Scope of Payment Services and E‑Money Can Now Be Interest‑Bearing

Excluding those denominated in foreign currency, balances held in payment and e-money safeguarding accounts, may be accrued with interest through an interest-bearing account with the bank where the relevant safeguarding accounts are maintained.

Following the deduction of commissions charged by the bank, as well as any other statutory deductions, the principal and the net accrual amount will be transferred to the relevant safeguarding account on the next business day. The applicable commission rate and the calculation methodology will be expressly set out in the client agreement. The principal and the accrual amount will be tracked separately, and the accrual amount may be freely used by the payment institution/e-money institution (the “Institution“).

The Institutions may not use these funds for any other purpose. In addition, the Institutions will be required to maintain a sufficient amount of funds to fulfill, without delay, their obligations arising from the provision of payment and e-money services. Following the transfer of the principal and the accrual amount back to the safeguarding accounts, the Institutions may, by the end of the same day, credit to their own accounts an amount corresponding to the payments made under this framework, without claiming any interest or similar financial benefit.

In the event that the operating license of an Institution is temporarily suspended, payment funds and funds collected in exchange for e-money that are held in safeguarding accounts may not be accrued interest during such period.

Accruals may only be carried out using low‑risk and liquid assets.

Amendments Regarding the Protection of Payment Funds

Under the Amending Regulation, it has been expressly stipulated that the rules applicable to requests directed to banks holding safeguarding accounts shall also apply to requests directed to banks holding accrual accounts for such funds. In this context, banks are required to comply with such requests only to the extent that they have information regarding the ultimate ownership of the payment funds on a customer basis and solely in relation to the relevant payment funds, and to notify the relevant institutions without delay.

In addition, the end‑of‑day cut‑off times used for the transfer of unpaid payment funds to safeguarding accounts have been updated and set at 4:30 p.m. on full business days and at 12:00 p.m. on half business days.

Amendments Regarding the Protection of Funds Collected in Exchange for E-Money

Under the Amending Regulation, it has been expressly provided that overnight accrual may be carried out with the bank where the e-money safeguarding account is maintained. It has also been stipulated that the end‑of‑day balance shall be determined in a manner consistent with the amount of e-money in circulation, based on the records of the institutions and the relevant bank account transactions.

In addition, it has been clarified that requests directed to banks holding not only the accounts in which funds received in exchange for the issuance of e-money are kept, but also the accounts through which such funds are remunerated, shall be complied with to the extent that the bank has information regarding the ultimate ownership of the funds on a customer basis and solely in relation to the relevant funds. Banks are required to notify the relevant institutions of such requests without delay.

Update of Administrative Monetary Fine Amounts

The administrative monetary fine amounts set out in Annex 13 to the Regulation have been updated. In this context, the administrative monetary fine applicable to foreign exchange purchase and sale transactions carried out independently of the provision of payment services has been redefined, pursuant to Law No. 1567, to range from TRY 719,000 to TRY 3,595,000.

Similarly, the administrative monetary fine amounts set out in Annex 14 to the Regulation have also been updated. Accordingly, foreign exchange purchase and sale transactions carried out independently of the provision of payment services and the issuance of e-money will be subject to an administrative monetary fine ranging from TRY 719,000 to TRY 3,595,000, pursuant to Law No. 1567.

Conclusion

The inability to accrue interest on funds used in payment services and e-money issuance was reducing the demand for payment services and e-money in an economic environment characterized by inflationary pressures and high deposit interest rates, and was preventing funds denominated in Turkish lira from being held in safeguarding accounts for extended periods. With the removal of the restriction on interest accrual, the fact that users will be able to hold funds in their accounts for longer periods is expected to increase interest in payment services and e-money.