New Obligations for Payment Services by the Central Bank of the Republic of Türkiye

The Central Bank of the Republic of Türkiye (“CBRT”) published the new regulations on 28 March 2025, titled “Regulation on Amendment to the Regulation on Payment Services and Issuance of Electronic Money and Payment Service Providers” (“Amendment Regulation”), which introduces significant changes to the existing Regulation on Payment Services and Issuance of Electronic Money and Payment Service Providers (“Regulation”).

The Communiqué Amending the Communiqué on the Information Systems of Payment and Electronic Money Institutions and on Data Sharing Services in the Field of Payment Services by Payment Service Providers was published concurrently in the Official Gazette. You can access our article on the amendment here.

I. Infrastructure Provision Obligation and Scope

With the Amendment Regulation, in line with the changes made in Article 59 of the Regulation, payment service providers that offer online access to payment accounts are now required to assume certain obligations. In this context:

• The provision regarding the deadline for payment service providers with payment accounts to connect to the Kart Merkezi A.Ş.after obtaining an operating license has been removed. Previously, this obligation only applied to entities with payment accounts; however, the scope has been extended, and now payment service providers that have payment accounts and offer direct online access to these accounts are also subject to this obligation.
• Article 59 of the Regulation has been amended to include a ninth paragraph, extending the relevant obligation to payment service providers that are participants in the Instant and Continuous Transfer System (“FAST”), as well as to non-participant providers ranking among the top ten annually in terms of total payment volume.
• For entities not participating in the FAST system, the payment volume will be assessed based on the data of the previous calendar year.
• Entities ranked among the top ten that do not currently offer online access to their customers are required to comply with these obligations within six months from the date on which such access is made available.
• Payment service providers that were not initially participants in the FAST system but subsequently joined are also required to comply with these obligations within six months from the date of their participation.

II. Regulations Regarding Compliance Deadlines

With the amendment made to the temporary Article 1 of the Regulation, the transition periods for fulfilling these obligations have been clarified:

• The deadline for fulfilling obligations for payment service providers that already have payment accounts and those that participate in the FAST system has been set to 31 December 2025.
• Payment service providers that are not participants in the FAST system but are among the top ten in payment volume as of 2024 must also fulfill the relevant obligations by 31 December 2025. Entities that enter the top ten in subsequent years are expected to complete these obligations by the end of the respective year.

III. Digital Wallet Service Compliance Obligation

With the amendment made to paragraph 19 of temporary Article 1 of the Regulation, the deadline for those providing digital wallet services before the enactment of Article 4/A of the Regulation, but not yet authorized as a payment institution or electronic money institution, to submit their necessary applications to the CBRT has been extended until 31 December 2025. Authorized institutions that are already providing digital wallet services must also comply with the provisions of Article 4/A of the Regulation by the same date.

The Amendment Regulation came into effect on 28 March 2025. You can access the full text of the Amendment Regulation here (Only available in Turkish).