New Crypto Regulations in Turkey: What You Need to Know (2025 Update)

Turkey has entered a new era of crypto regulation.
With the new laws enacted in 2024 and 2025, crypto asset service providers (CASPs) operating in Turkey must now comply with strict rules issued by the Capital Markets Board (CMB).

This article explains the new rules clearly and simply.

Background: New Crypto Law in Turkey

• Law No. 7518 amended the Capital Markets Law.

• As of July 2, 2024, crypto companies are officially regulated under the CMB.

• Two main communiqués were published:

  • Communiqué No. III-35/B.1: Rules for the establishment and operation of CASPs.

  • Communiqué No. III-35/B.2: Rules for activities, services, and financial requirements.

Setting Up a Crypto Company in Turkey (Communiqué III-35/B.1)

To establish a crypto company in Turkey:

• You must form a joint-stock company.

• All company shares must be registered shares.

• The initial capital must be fully paid in cash.

• The shareholding structure must be transparent.

• The company’s articles of association must comply with the Capital Markets Law.

• Your trade name must include either "crypto asset trading platform" or "crypto asset custody institution" depending on the services you offer.

Founders must also meet strict eligibility criteria regarding financial and criminal records.

Licensing Requirements

You cannot operate without official authorization.
Crypto companies must follow a two-step process:

1. Apply for an establishment license from the CMB.

2. Apply for an operating license after establishment.

If you do not apply for the operating license within six months, you lose your right to proceed.
You must also obtain an authorization certificate before starting any business operations.

Company Structure and Management

CASPs must build a strong organizational structure including:

• Internal audit, internal control, and risk management units.

• A general manager living full-time in Turkey and working exclusively for the company.

• Managers and staff with at least a four-year university degree.

• A board of directors with at least three members, the majority of whom are university graduates.

Specific experience requirements also apply to general managers and senior executives.

Shareholding Changes: Approvals and Notifications

If a shareholder acquires or sells:

• 10%, 20%, 33%, or 50% or more of the company shares or voting rights,

you must obtain prior approval from the CMB.

Even if these thresholds are not reached, transfers involving special rights (such as board representation) must still be approved.
Smaller share changes must be notified to the CMB within ten business days.

Integration and Membership Obligations

Crypto companies must:

• Integrate with the Central Securities Depository (CSD) of Turkey.

• Become members of the Turkish Capital Markets Association.

• Disclose detailed company information publicly through the Public Disclosure Platform and on their website.

Customer Agreements

Before any transaction takes place, platforms must sign a clear service agreement with their customers, outlining all rights and obligations.

Outsourcing Restrictions

Crypto companies are allowed to outsource some services but cannot outsource:

• Board of Directors’ exclusive responsibilities.

• Activities requiring CMB authorization.

• Financial reporting and accounting services.

• Internal audit, internal control, and risk management functions.

Strict guidelines apply to any permitted outsourcing activities.

Custody Services Regulation

Specific rules are introduced for custody services:

• Companies providing custody must set up a dedicated internal unit.

• Only authorized custody institutions and banks may offer custody services.

• Safeguarding clients’ crypto assets is a top regulatory priority.

Transitional Periods and Deadlines

Existing platforms must:

• Apply for their operating licenses by June 30, 2025.

• Obtain authorization certificates by June 30, 2026.

Other rules become effective between March 31, 2025, and June 30, 2025, depending on the subject matter.

Financial Requirements for Crypto Companies (Communiqué III-35/B.2)

New capital requirements are as follows:

Key points:

• CASPs' equity must never fall below their initial capital.

• Custody institutions holding over TRY 1 billion in client assets must add extra equity equivalent to 1.5% of the surplus.

Authorized Services for Crypto Companies

With CMB authorization, CASPs can:

• Execute crypto asset buy/sell orders.

• Facilitate crypto asset transfers and custody.

• Manage initial coin offerings and token sales.

• Provide investment advisory services.

• Carry out other CMB-approved crypto-related services.

All services must be performed according to CMB rules and regulations.

Platform Activity Requirements

Platforms must:

• Build a secure trading environment.

• Establish systems to monitor price changes.

• Comply with rules for leveraged, credit, and derivative transactions.

• Follow clear policies for order execution and client asset transfers.

• Establish strong reporting practices for any special market events.

Listing and Delisting Crypto Assets

Platforms must:

• Set up a listing committee.

• Establish clear criteria for listing and delisting crypto assets.

• Regularly monitor and update their listed assets.

Custody and Transfer Rules

Platforms and custody institutions must:

• Properly secure crypto assets and private keys.

• Execute client transfer orders transparently and securely.

• Integrate their records with the Central Securities Depository (CSD) system.

Additional Transitional Rules

Platforms listed on the "Operating Entities List" as of March 13, 2025, must:

• Upgrade their custody systems by June 30, 2025.

• Meet capital and equity requirements when applying for an operating license.

Some provisions entered into force on March 13, 2025, while others will become mandatory by June 30, 2025.

Conclusion

The new crypto regulations in Turkey mark a significant step toward a safer and more transparent crypto environment.
If you are operating a crypto platform or planning to launch one, understanding and following these regulations is critical.

Non-compliance could result in heavy penalties or license revocation.
Act early to ensure your crypto business aligns with Turkish regulatory standards.

Need Professional Assistance?

If you need help establishing your crypto company in Turkey or navigating the new regulations, our team of experts is ready to assist you.

Contact us today for a free initial consultation.

Email: info@ozmconsultancy.com
Phone: +90 216 352 29 61