Turkey Crypto Licence (CMB / SPK) 2026

Overview

Turkey's CASP Licensing Regime — Law No. 7518

In July 2024, Turkey enacted Law No. 7518, amending the Capital Markets Law to create a complete CASP licensing regime. The CMB (Sermaye Piyasası Kurulu / SPK) is the sole regulator. Turkey is one of the world's most active crypto markets, ranking in the top 5 globally by trading volume per capita — driven by economic conditions and high retail adoption.

All existing platforms must obtain authorisation; new entrants must apply before commencing operations. Unlicensed platforms face criminal sanctions under Turkish law. The CMB has established a transition period for existing operators, but the deadline for full compliance has passed, meaning all active platforms must now hold or be in the process of obtaining a CASP licence.

The Turkish CASP framework draws on international standards including FATF recommendations and EU MiCA principles, with specific adaptations for the Turkish market and regulatory environment. The CMB has authority to set and adjust capital requirements by regulation.

Capital requirement: CMB Communiqué III-35/B.2 (Official Gazette, 13 March 2025) sets minimum founding capital at TRY 150,000,000 for a crypto asset trading platform and TRY 500,000,000 for a custodian, paid in full in cash. The CMB can raise these amounts each year in line with the revaluation rate announced by the Ministry of Treasury and Finance.

Licence Categories

Turkish CASP — Authorized Activities

Under Law No. 7518, a single CASP licence can cover multiple activity types. Platforms apply for authorisation for each specific activity they intend to conduct. The CMB grants authorisation per activity category.

Activity	Turkish Term	Description
Crypto Asset Exchange	Kripto varlık alım satım platformu	Operating a trading platform for crypto assets (fiat and crypto pairs)
Crypto Asset Custody	Saklama hizmeti	Safekeeping and administering crypto assets on behalf of clients
Crypto Asset Transfer	Transfer hizmeti	Executing crypto transfers and settlements between wallets/accounts
Portfolio Management	Portföy yönetimi	Managing crypto asset portfolios on behalf of clients

Requirements

Turkish CASP Licence — Key Requirements

Entity

Turkish joint-stock company (A.Ş.)

Foreign subsidiaries must be incorporated in Turkey as A.Ş.

Min. Capital

TRY 150,000,000 paid-up

Trading platform; TRY 500,000,000 for a custodian, paid in cash

Board Composition

Minimum 3 board members

Majority must be Turkish residents; relevant expertise required

Shareholders

Fit & proper for 10%+ holders

Background checks and financial standing assessment

Compliance & MLRO

Chief Compliance Officer and MLRO required

Turkish regulatory knowledge required for both roles

Client Funds

Segregated client funds mandatory

Held separately from company assets at all times

Custody (if applicable)

Cold storage requirements

Minimum percentage of client assets in cold storage

Technology

Audit and cybersecurity assessment

Independent technology audit required before licence issuance

Process

How to Get a Turkish CASP Licence — Step by Step

1

Incorporate Turkish A.Ş. and Meet Capital Requirements

Establish a Turkish joint-stock company (Anonim Şirket) with the Turkish Trade Registry. Pay in the minimum capital in cash: TRY 150,000,000 for a trading platform or TRY 500,000,000 for a custodian. Appoint the required number of board members (minimum 3), ensuring the majority are Turkish residents with relevant expertise.

4–6 weeks

2

Prepare CASP Application Package

Develop the complete application: detailed business plan, technology architecture assessment, AML/CFT policies aligned with Turkish AML law, organizational charts, risk management framework, customer fund segregation procedures, and cold storage policy (for custodians). This is the most time-intensive phase.

8–12 weeks

3

File Application with CMB

Submit the complete CASP application to the CMB (SPK) along with the required TRY application fee. The CMB will acknowledge receipt and assign a case officer. Ensure all documentation is in Turkish or officially translated — the CMB conducts all correspondence in Turkish.

Week 12–14

4

CMB Review and Additional Information Requests

The CMB conducts a thorough review, including background checks on all key persons, assessment of the business plan, and technology evaluation. Expect multiple rounds of additional information requests (AIRs). Respond fully to all CMB queries within stated deadlines.

3–6 months

5

CMB Decision and Licence Issuance

Upon satisfactory review, the CMB issues the CASP authorisation. Ongoing obligations include monthly CMB reporting, annual independent audit, AML/CFT reviews, and immediate notification of material changes. The CMB conducts periodic on-site inspections of licensed entities.

Final approval

Costs

Turkish CASP Licence — Cost Overview

Item	Details	Approx. Cost
Company formation (A.Ş.)	Trade registry, notary, constitutional documents	USD 2,000–5,000
CMB application fee	Regulated fee (TRY 500,000+)	TRY 500,000+
Legal & compliance preparation	Application package, policies, Turkish counsel	USD 20,000–50,000
Technology audit	Independent cybersecurity and systems assessment	USD 10,000–20,000
Operational capital (mandatory)	Minimum paid-up capital requirement	TRY 150,000,000 (platform) / TRY 500,000,000 (custodian)
Professional advisory fees	End-to-end CASP application support	On request
Estimated professional costs (excl. capital)	Setup, legal, compliance, technology audit	USD 35,000–80,000+

FAQ

Turkish CASP Licence — Common Questions

Yes. Since 2024, all crypto asset service providers operating in Turkey must be licensed by the Capital Markets Board (CMB / SPK) under Law No. 7518. Unlicensed platforms are prohibited and face criminal sanctions under Turkish law. The CMB has been actively enforcing these requirements against non-compliant operators.

CMB Communiqué III-35/B.2 sets minimum founding capital at TRY 150,000,000 for a crypto asset trading platform and TRY 500,000,000 for a custodian, paid in full in cash. The CMB can raise these amounts each year in line with the official revaluation rate.

No. A Turkish CASP must be incorporated as a Turkish joint-stock company (Anonim Şirket / A.Ş.). Foreign companies must establish a Turkish subsidiary. Branch operations by foreign entities are not permitted for CASP activities. The subsidiary must have genuine local presence, including Turkish-resident majority board members.

The full process from company formation to licence issuance typically takes 6–12 months. CMB review alone takes 3–6 months. Preparation of the application package (business plan, compliance docs, technology assessment) typically takes 2–3 months before filing. Thorough preparation of documentation reduces the likelihood of additional information requests, which can significantly extend timelines.

Operating a crypto exchange, providing crypto custody, executing crypto transfers, and offering crypto asset portfolio management all require a CMB CASP licence. Providing information services or wallets without holding client funds may be exempt, pending CMB guidance. Any activity involving Turkish clients or Turkish lira transactions requires CMB authorisation.

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