Turkey Crypto License (CMB / SPK) — CASP Requirements 2026

Bitcoin altcoins 200 euro notes gold — Turkey Crypto License: CMB CASP Framework 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 comprehensive 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 authorization; 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 license.

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.

License Categories

Turkish CASP — Authorized Activities

Under Law No. 7518, a single CASP license can cover multiple activity types. Platforms apply for authorization for each specific activity they intend to conduct. The CMB grants authorization 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 License — Key Requirements

Entity

Turkish joint-stock company (A.Ş.)

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

Min. Capital

TRY 50,000,000 paid-up

Approx. USD 1.5M+ at current rates; CMB may adjust

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 license issuance

Process

How to Get a Turkish CASP License — Step by Step

Incorporate Turkish A.Ş. and Meet Capital Requirements

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 weeks

Prepare CASP Application Package

Develop the comprehensive 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

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

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 comprehensively to all CMB queries within stated deadlines.

3–6 months

CMB Decision and License Issuance

Upon satisfactory review, the CMB issues the CASP authorization. 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 License — 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+

FAQ

Turkish CASP License — 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.

The CMB requires a minimum paid-up share capital of TRY 50,000,000 (approximately USD 1.5 million at current rates). The CMB may adjust this threshold periodically by regulation. Given Turkish lira volatility, applicants should obtain current legal advice on the USD equivalent requirement and consider the capital injection strategy carefully.

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 license 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 license. 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 authorization.

Total costs typically range from 150,000 to 300,000 EUR, including application fees to the CMB (Capital Markets Board), legal and consulting fees, compliance infrastructure setup, and initial capital requirements. The CMB application fee itself is approximately 5,000 EUR, but the majority of costs come from meeting operational and capital requirements. Costs can vary based on your specific business model and the complexity of your compliance framework.

You must establish accounts with Turkish banks that accept crypto-related businesses, as many traditional banks still avoid the sector. Pre-approval from at least one major Turkish bank (such as Akbank, Garanti, or Denizbank) demonstrating willingness to service your CASP operations is typically required by the CMB. We recommend initiating banking relationships 3-4 months before your CMB application, as Turkish banks increasingly scrutinize crypto service providers in 2026.

Yes, the CMB requires compliance with internationally recognized cybersecurity standards including ISO 27001 certification for information security management systems. You must implement multi-signature wallets, cold storage solutions for customer assets, penetration testing at least annually, and incident response protocols. Additionally, you need a dedicated Chief Information Security Officer or equivalent role and must maintain cyber liability insurance of at least 500,000 EUR as of 2026.

Licensed CASPs are subject to corporate income tax at 20% on profits, plus 15% VAT on services provided, though some exemptions may apply depending on your specific activities. Cryptocurrency gains themselves are treated as ordinary income subject to personal income tax rates (15-40% progressive scale) for individual traders, while corporate entities pay the standard 20% rate. You must maintain detailed transaction records for all customer activities and file quarterly tax returns with the Turkish Revenue Administration.

License revocation by the CMB typically results in a 6-month wind-down period to settle customer accounts and transfer assets, during which you cannot accept new customers or services. Grounds for revocation include failure to maintain minimum capital, material compliance breaches, money laundering violations, or misrepresentation in applications. You may appeal revocation decisions to the Turkish administrative courts, but this process can take 12-24 months and does not suspend the revocation order.

Turkish CASP licenses must be renewed annually with the CMB, requiring submission of audited financial statements, updated compliance certifications, and proof of maintained capital requirements. The renewal process typically takes 4-8 weeks and costs approximately 2,000-5,000 EUR in administrative and audit fees. Failure to renew by the deadline results in automatic license suspension, so applications should be submitted at least 60 days before expiration.

The CMB mandates comprehensive KYC procedures including government-issued ID verification, proof of address, beneficial ownership documentation, and source of funds verification for all customers. Enhanced Due Diligence (EDD) is required for high-risk customers, politically exposed persons (PEPs), and transactions exceeding 50,000 EUR. All documentation must be retained for a minimum of 5 years and made available for regulatory inspections, with monthly AML transaction monitoring and reporting to the Financial Crimes Investigation Board (MASAK).

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◆ KEY METRICS

Turkey CASP License Requirements at a Glance

₺5,000,000

Minimum Capital Requirement

90–120 Days

Processing Timeline

₺250,000–500,000

Application & License Fee

15% / 20%

Corporate Income Tax Rate

CMB (SPK)

Regulator Authority

Multi-Activity Single License

Key Advantage

◆ PROCESS ROADMAP

Turkey CASP Licensing Timeline (2026)

Week 1–2

Entity Formation & Documentation

Establish Turkish legal entity (JSC/Limited Company), prepare Articles of Association, ownership structure, AML/KYC policies, and IT security framework.

Week 3–4

Capital Deposit & CMB Pre-Filing

Deposit minimum ₺5,000,000 into bank account, obtain bank certificate, prepare operational manual, compliance framework, and activity scope matrix.

Week 5–6

Formal Application Submission

Submit complete application package to CMB (SPK) with all required documentation, including activity authorizations and technical specifications for each service type.

Month 2–3

CMB Review & Clarifications

CMB conducts completeness review, requests clarifications or additional documentation, evaluates compliance infrastructure, management credentials, and risk management systems.

Month 4

License Issuance & Go-Live

Receive CMB authorization decision, obtain formal license certificate, pay final fees, and commence authorized crypto asset services in Turkey.

Turkey Crypto License: CMB CASP Framework 2026