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 note: The TRY 50,000,000 minimum capital requirement is subject to regular review by the CMB. Given Turkish lira volatility, applicants should verify the current USD equivalent with legal counsel before committing capital. The CMB may adjust this in USD-equivalent terms.
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 |
Turkish CASP Licence — Key Requirements
How to Get a Turkish CASP Licence — Step by Step
Establish a Turkish joint-stock company (Anonim Şirket) with the Turkish Trade Registry. Inject the minimum paid-up capital of TRY 50,000,000. Appoint the required number of board members (minimum 3), ensuring the majority are Turkish residents with relevant expertise.
4–6 weeksDevelop 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 weeksSubmit 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 12–14The 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 monthsUpon 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 approvalTurkish 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 50,000,000+ |
| 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+ |