Turkey -- Securities Classification Regulatory Overview
Methodology
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RESEARCH: Turkey Securities Treatment
Executive Summary
- Crypto assets are legal in Turkey but not classified as securities under the Capital Markets Law; the Capital Markets Board (SPK) regulates crypto-asset service providers (CASPs) under a dedicated framework enacted in 2024–2025 Türkiye Introduces New Crypto Asset Regulations: A Landmark Development in Digital Finance.
- The SPK (Capital Markets Board of Turkey) is the primary regulator; it issues licences for CASPs and supervises compliance with the Communiqué on Operational Principles and Capital Adequacy Crypto Licensing in Turkey: Essential 2026 Guide to Secure Exchanges | TENHA LAW FIRM - TENHA.
- Licensing is mandatory for exchanges, custodians, and other CASPs; as of early 2025 the SPK was conducting fit-and-proper assessments on applicants but no public list of fully licensed entities has been published Turkey – Blockchain & Crypto Assets – Country Comparative Guides.
- AML/KYC obligations fall under MASAK (Financial Crimes Investigation Board) and align with FATF standards; CASPs must perform CDD, EDD, STR filing, and beneficial-ownership checks Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
- Tax treatment remains unclear: no specific tax guidance for virtual assets has been issued; gains may be subject to income tax under general provisions but capital-gains and VAT rules are not defined Cryptocurrency Regulations in Turkey: Legal Overview for Investors and Exchanges.
Regulatory Framework
- Regulator: Capital Markets Board of Turkey (SPK / CMB) — website: https://www.spk.gov.tr/ Crypto Licensing in Turkey: Essential 2026 Guide to Secure Exchanges | TENHA LAW FIRM - TENHA.
- Primary legislation: Law No. 7518 on Amendments to the Capital Markets Law (published 2 July 2024) and the Communiqué on Operational Principles and Capital Adequacy of Crypto Asset Service Providers (Communiqué Serial: III, No. 35.1, effective 2025) THE QUALIFICATION OF CRYPTO-ASSETS AS SECURITIES UNDER TURKISH LAW: A COMPARATIVE ANALYSIS - The Boğaziçi Law Review.
- Crypto assets are explicitly excluded from the definition of “securities” under the Capital Markets Law; they are regulated as a separate asset class under the new CASP regime THE QUALIFICATION OF CRYPTO-ASSETS AS SECURITIES UNDER TURKISH LAW: A COMPARATIVE ANALYSIS - The Boğaziçi Law Review.
- International standing: Turkey is a FATF member; its mutual evaluation (2024) noted progress on VASP regulation but highlighted supervisory effectiveness gaps Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
Licensing Requirements
- Activities requiring a CASP licence: exchange services, custody, transfer, portfolio management, and investment advice related to crypto assets Expert Guide on Crypto Regulation and Compliance in Turkiye.
- Minimum capital requirement: TRY 50 million (≈ EUR 1.4 million / USD 1.5 million at 2025 rates) for exchanges; lower thresholds for custodians and other service types Crypto Licensing in Turkey: Essential 2026 Guide to Secure Exchanges | TENHA LAW FIRM - TENHA.
- Application process: submission to SPK with business plan, IT security audit, AML/CTF policies, fit-and-proper declarations for shareholders and managers; SPK conducts on-site inspections Turkey – Blockchain & Crypto Assets – Country Comparative Guides.
- Timeline: SPK aims to decide within 6 months of complete application; as of April 2026 no public register of granted licences exists Turkey – Blockchain & Crypto Assets – Country Comparative Guides.
- Structural requirements: Turkish joint-stock company (A.Ş.) with minimum two founders, local headquarters, and at least one board member resident in Turkey Expert Guide on Crypto Regulation and Compliance in Turkiye.
- Zero licences publicly confirmed as of 2026-04-18; SPK is still processing applications and conducting audits Turkey – Blockchain & Crypto Assets – Country Comparative Guides.
AML/KYC Requirements
- CASPs are “obliged parties” under Law No. 5549 (Prevention of Laundering Proceeds of Crime) and must comply with MASAK Communiqué No. 19 (2021, updated 2024) Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
- Customer Due Diligence (CDD) mandatory for all users; Enhanced Due Diligence (EDD) for PEPs, high-risk jurisdictions, and transactions above TRY 75,000 (≈ EUR 2,100) Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
- Suspicious Transaction Reports (STRs) must be filed to MASAK “without delay”; no de minimis threshold Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
- Record retention: 8 years from end of business relationship or transaction Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
- Beneficial ownership identification required for legal entities; threshold 25% voting rights or control Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
- PEP screening: domestic and foreign PEPs, family members, close associates; ongoing monitoring required Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
Enforcement Actions
- SPK issued administrative fines to 12 unlicensed platforms in 2024–2025 for operating without CASP authorisation; fines ranged from TRY 500,000 to TRY 10 million (≈ EUR 14,000–280,000) Cryptocurrency Regulations in Türkiye - Sanction Scanner.
- MASAK levied a TRY 8 million fine (≈ EUR 225,000) on a local exchange in March 2025 for deficient STR filing and inadequate CDD Cryptocurrency Regulations in Türkiye - Sanction Scanner.
- No criminal arrests of CASP executives reported; enforcement remains administrative Cryptocurrency Regulations in Türkiye - Sanction Scanner.
Tax Treatment
- No tax guidance has been issued for virtual assets; the Revenue Administration has not published a communiqué on crypto taxation Cryptocurrency Regulations in Turkey: Legal Overview for Investors and Exchanges.
- General income tax (15–40% progressive) may apply to trading gains if deemed commercial earnings; capital-gains treatment and VAT exemption are unresolved Cryptocurrency Regulations in Turkey: Legal Overview for Investors and Exchanges.
Key Gaps & Risks
- Licensing backlog: SPK has not published any approved CASP licences, creating regulatory uncertainty for market entrants Turkey – Blockchain & Crypto Assets – Country Comparative Guides.
- Securities classification ambiguity: while crypto assets are excluded from the securities definition, tokenised securities and investment contracts may still fall under Capital Markets Law, creating overlap risk THE QUALIFICATION OF CRYPTO-ASSETS AS SECURITIES UNDER TURKISH LAW: A COMPARATIVE ANALYSIS - The Boğaziçi Law Review.
- Tax vacuum: absence of specific rules exposes businesses to retrospective assessments and double-taxation disputes Cryptocurrency Regulations in Turkey: Legal Overview for Investors and Exchanges.
- Custody standards: the Communiqué mandates minimum security requirements for IT infrastructure and custody solutions but detailed technical standards are pending Türkiye Introduces New Crypto Asset Regulations: A Landmark Development in Digital Finance.
- Cross-border access: unlicensed foreign platforms remain accessible; SPK relies on IP blocking and payment-service-provider restrictions, which are easily circumvented Turkey: Blockchain & Crypto Assets – Country Comparative Guides.
Sources
- Cryptocurrency Regulations in Türkiye - Sanction Scanner
- THE QUALIFICATION OF CRYPTO-ASSETS AS SECURITIES UNDER TURKISH LAW: A COMPARATIVE ANALYSIS - The Boğaziçi Law Review
- Expert Guide on Crypto Regulation and Compliance in Turkiye
- Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber
- Crypto Licensing in Turkey: Essential 2026 Guide to Secure Exchanges | TENHA LAW FIRM - TENHA
- The Legal Regime of Crypto Assets in Turkey and the Role of Regulatory Institutions – Legal Developments
- Turkey – Blockchain & Crypto Assets – Country Comparative Guides
- Turkey: Blockchain & Crypto Assets – Country Comparative Guides
- Cryptocurrency Regulations in Turkey: Legal Overview for Investors and Exchanges
- Turkey Crypto Exchange Regulations 2026: Binance, Bitget, Coinbase Guide
- Crypto Asset Custody in Turkey: Regulatory Overview and Compliance Insights (2025)
- Türkiye Introduces New Crypto Asset Regulations: A Landmark Development in Digital Finance
Source Data
Crypto assets are legal in Turkey but not classified as securities under the Capital Markets Law; the Capital Markets Board (SPK) regulates crypto-asset service providers (CASPs) under a dedicated framework enacted in 2024–2025 Türkiye Introduces New Crypto Asset Regulations: A Landmark Development in Digital Finance.
The SPK (Capital Markets Board of Turkey) is the primary regulator; it issues licences for CASPs and supervises compliance with the Communiqué on Operational Principles and Capital Adequacy Crypto Licensing in Turkey: Essential 2026 Guide to Secure Exchanges | TENHA LAW FIRM - TENHA.
Licensing is mandatory for exchanges, custodians, and other CASPs; as of early 2025 the SPK was conducting fit-and-proper assessments on applicants but no public list of fully licensed entities has been published Turkey – Blockchain & Crypto Assets – Country Comparative Guides.
AML/KYC obligations fall under MASAK (Financial Crimes Investigation Board) and align with FATF standards; CASPs must perform CDD, EDD, STR filing, and beneficial-ownership checks Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
Tax treatment remains unclear: no specific tax guidance for virtual assets has been issued; gains may be subject to income tax under general provisions but capital-gains and VAT rules are not defined Cryptocurrency Regulations in Turkey: Legal Overview for Investors and Exchanges.
Regulator: Capital Markets Board of Turkey (SPK / CMB) — website: https://www.spk.gov.tr/ Crypto Licensing in Turkey: Essential 2026 Guide to Secure Exchanges | TENHA LAW FIRM - TENHA.
Primary legislation: Law No. 7518 on Amendments to the Capital Markets Law (published 2 July 2024) and the Communiqué on Operational Principles and Capital Adequacy of Crypto Asset Service Providers (Communiqué Serial: III, No. 35.1, effective 2025) THE QUALIFICATION OF CRYPTO-ASSETS AS SECURITIES UNDER TURKISH LAW: A COMPARATIVE ANALYSIS - The Boğaziçi Law Review.
Crypto assets are explicitly excluded from the definition of “securities” under the Capital Markets Law; they are regulated as a separate asset class under the new CASP regime THE QUALIFICATION OF CRYPTO-ASSETS AS SECURITIES UNDER TURKISH LAW: A COMPARATIVE ANALYSIS - The Boğaziçi Law Review.
International standing: Turkey is a FATF member; its mutual evaluation (2024) noted progress on VASP regulation but highlighted supervisory effectiveness gaps Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
Activities requiring a CASP licence: exchange services, custody, transfer, portfolio management, and investment advice related to crypto assets Expert Guide on Crypto Regulation and Compliance in Turkiye.
Minimum capital requirement: TRY 50 million (≈ EUR 1.4 million / USD 1.5 million at 2025 rates) for exchanges; lower thresholds for custodians and other service types Crypto Licensing in Turkey: Essential 2026 Guide to Secure Exchanges | TENHA LAW FIRM - TENHA.
Application process: submission to SPK with business plan, IT security audit, AML/CTF policies, fit-and-proper declarations for shareholders and managers; SPK conducts on-site inspections Turkey – Blockchain & Crypto Assets – Country Comparative Guides.
Timeline: SPK aims to decide within 6 months of complete application; as of April 2026 no public register of granted licences exists Turkey – Blockchain & Crypto Assets – Country Comparative Guides.
Structural requirements: Turkish joint-stock company (A.Ş.) with minimum two founders, local headquarters, and at least one board member resident in Turkey Expert Guide on Crypto Regulation and Compliance in Turkiye.
Zero licences publicly confirmed as of 2026-04-18; SPK is still processing applications and conducting audits Turkey – Blockchain & Crypto Assets – Country Comparative Guides.
CASPs are “obliged parties” under Law No. 5549 (Prevention of Laundering Proceeds of Crime) and must comply with MASAK Communiqué No. 19 (2021, updated 2024) Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
Customer Due Diligence (CDD) mandatory for all users; Enhanced Due Diligence (EDD) for PEPs, high-risk jurisdictions, and transactions above TRY 75,000 (≈ EUR 2,100) Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
Suspicious Transaction Reports (STRs) must be filed to MASAK “without delay”; no de minimis threshold Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
Record retention: 8 years from end of business relationship or transaction Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
Beneficial ownership identification required for legal entities; threshold 25% voting rights or control Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
PEP screening: domestic and foreign PEPs, family members, close associates; ongoing monitoring required Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber.
SPK issued administrative fines to 12 unlicensed platforms in 2024–2025 for operating without CASP authorisation; fines ranged from TRY 500,000 to TRY 10 million (≈ EUR 14,000–280,000) Cryptocurrency Regulations in Türkiye - Sanction Scanner.
MASAK levied a TRY 8 million fine (≈ EUR 225,000) on a local exchange in March 2025 for deficient STR filing and inadequate CDD Cryptocurrency Regulations in Türkiye - Sanction Scanner.
No criminal arrests of CASP executives reported; enforcement remains administrative Cryptocurrency Regulations in Türkiye - Sanction Scanner.
No tax guidance has been issued for virtual assets; the Revenue Administration has not published a communiqué on crypto taxation Cryptocurrency Regulations in Turkey: Legal Overview for Investors and Exchanges.
General income tax (15–40% progressive) may apply to trading gains if deemed commercial earnings; capital-gains treatment and VAT exemption are unresolved Cryptocurrency Regulations in Turkey: Legal Overview for Investors and Exchanges.
Licensing backlog: SPK has not published any approved CASP licences, creating regulatory uncertainty for market entrants Turkey – Blockchain & Crypto Assets – Country Comparative Guides.
Securities classification ambiguity: while crypto assets are excluded from the securities definition, tokenised securities and investment contracts may still fall under Capital Markets Law, creating overlap risk THE QUALIFICATION OF CRYPTO-ASSETS AS SECURITIES UNDER TURKISH LAW: A COMPARATIVE ANALYSIS - The Boğaziçi Law Review.
Tax vacuum: absence of specific rules exposes businesses to retrospective assessments and double-taxation disputes Cryptocurrency Regulations in Turkey: Legal Overview for Investors and Exchanges.
Custody standards: the Communiqué mandates minimum security requirements for IT infrastructure and custody solutions but detailed technical standards are pending Türkiye Introduces New Crypto Asset Regulations: A Landmark Development in Digital Finance.
Cross-border access: unlicensed foreign platforms remain accessible; SPK relies on IP blocking and payment-service-provider restrictions, which are easily circumvented Turkey: Blockchain & Crypto Assets – Country Comparative Guides.
Cryptocurrency Regulations in Türkiye - Sanction Scanner
THE QUALIFICATION OF CRYPTO-ASSETS AS SECURITIES UNDER TURKISH LAW: A COMPARATIVE ANALYSIS - The Boğaziçi Law Review
Expert Guide on Crypto Regulation and Compliance in Turkiye
Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber
Crypto Licensing in Turkey: Essential 2026 Guide to Secure Exchanges | TENHA LAW FIRM - TENHA
The Legal Regime of Crypto Assets in Turkey and the Role of Regulatory Institutions – Legal Developments
Turkey – Blockchain & Crypto Assets – Country Comparative Guides
Turkey: Blockchain & Crypto Assets – Country Comparative Guides
Cryptocurrency Regulations in Turkey: Legal Overview for Investors and Exchanges
Turkey Crypto Exchange Regulations 2026: Binance, Bitget, Coinbase Guide
Crypto Asset Custody in Turkey: Regulatory Overview and Compliance Insights (2025)
Türkiye Introduces New Crypto Asset Regulations: A Landmark Development in Digital Finance
References
This article was generated by openrouter/nvidia/nemotron-3-ultra-550b-a55b:free .
Primary Sources
SPK/CMB. (n.d.). SPK/CMB. Retrieved April 9, 2026, from https://spk.gov.tr tr
MASAK. (n.d.). MASAK. Retrieved April 9, 2026, from https://masak.gov.tr tr
www.resmigazete.gov.tr. (n.d.). www.resmigazete.gov.tr. Retrieved April 22, 2026, from https://www.resmigazete.gov.tr/eskiler/2021/04/20210416-3.htm tr
www.resmigazete.gov.tr. (n.d.). www.resmigazete.gov.tr. Retrieved April 22, 2026, from https://www.resmigazete.gov.tr/eskiler/2024/07/20240702-1.htm tr
www.resmigazete.gov.tr. (n.d.). www.resmigazete.gov.tr. Retrieved April 22, 2026, from https://www.resmigazete.gov.tr/ tr
dergipark.org.tr. (n.d.). THE QUALIFICATION OF CRYPTO-ASSETS AS SECURITIES UNDER TURKISH LAW: A COMPARATIVE ANALYSIS - The Boğaziçi Law Review. Retrieved September 6, 2026, from https://dergipark.org.tr/en/pub/blr/article/1838778 tr
spk.gov.tr. (n.d.). www.spk.gov.tr. Retrieved September 6, 2026, from https://www.spk.gov.tr/ tr
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cms.law. (n.d.). Türkiye Introduces New Crypto Asset Regulations: A Landmark Development in Digital Finance. Retrieved September 6, 2026, from https://cms.law/en/tur/legal-updates/tuerkiye-introduces-new-crypto-asset-regulations-a-landmark-development-in-digital-finance
tenha.av.tr. (n.d.). Crypto Licensing in Turkey: Essential 2026 Guide to Secure Exchanges | TENHA LAW FIRM - TENHA. Retrieved September 6, 2026, from https://tenha.av.tr/crypto-licensing-in-turkey/ tr
legal500.com. (n.d.). Turkey – Blockchain & Crypto Assets – Country Comparative Guides. Retrieved September 6, 2026, from https://www.legal500.com/guides/legal-landscapes/turkey-blockchain-crypto-assets/
sumsub.com. (n.d.). Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber. Retrieved September 6, 2026, from https://sumsub.com/blog/crypto-regulations-turkey/
istanbullawyerfirm.com. (n.d.). Cryptocurrency Regulations in Turkey: Legal Overview for Investors and Exchanges. Retrieved September 6, 2026, from https://istanbullawyerfirm.com/blog/cryptocurrency-regulations-in-turkey-a-legal-overview
cms.law. (n.d.). Expert Guide on Crypto Regulation and Compliance in Turkiye. Retrieved September 6, 2026, from https://cms.law/en/int/expert-guides/cms-expert-guide-to-crypto-regulation/turkiye
sanctionscanner.com. (n.d.). Cryptocurrency Regulations in Türkiye - Sanction Scanner. Retrieved September 6, 2026, from https://www.sanctionscanner.com/blog/cryptocurrency-regulations-in-turkiye-1167
legal500.com. (n.d.). Turkey: Blockchain & Crypto Assets – Country Comparative Guides. Retrieved September 6, 2026, from https://www.legal500.com/guides/chapter/turkey-blockchain-crypto-assets/
legal500.com. (n.d.). The Legal Regime of Crypto Assets in Turkey and the Role of Regulatory Institutions – Legal Developments. Retrieved September 6, 2026, from https://www.legal500.com/developments/thought-leadership/the-legal-regime-of-crypto-assets-in-turkey-and-the-role-of-regulatory-institutions/
bitget.com. (n.d.). Turkey Crypto Exchange Regulations 2026: Binance, Bitget, Coinbase Guide. Retrieved September 6, 2026, from https://www.bitget.com/academy/turkey-crypto-rules
arclaw.services. (n.d.). Crypto Asset Custody in Turkey: Regulatory Overview and Compliance Insights (2025). Retrieved September 6, 2026, from https://arclaw.services/crypto-asset-custody-turkey/
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