Business Model
As it is known, the business models referred to as 'Closed Loop Wallet/Card' and/or 'Marketplace Exception' in the FinTech sector, which are mostly seen in the e-commerce and food card sectors, are included in the 'Commercial Agent" and/or 'Limited Network' exceptions under Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions.
Obligation
With the Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers that entered into force on 2021 December, service providers conducting the aforementioned business models outside the scope of Law No. 6493 are obliged to report to the Central Bank of Turkey ("TCMB") every year in January on the relevant business model if the amount of transactions carried out within the last twelve months in this scope exceeds fifty million Turkish Liras.
Reporting Scope
Pursuant to the legislation, the relevant reporting should include information on the definition of the service provided, detailed business flows and models, transaction volumes, average, minimum and maximum transaction amounts, customer and merchant network, the number and type of merchants to which they apply, the geographical distribution of these merchants and the conditions under which they fulfil the relevant business models.
The relevant reporting should be made in the format published by the TCMB.
Deadline
The deadline for reporting to the TCMB ends at the close of business on the last business day of January.
Due to the detailed scope of the relevant reporting, companies with the aforementioned business models should consolidate the necessary metrics and information as soon as possible and report in the format requested by the TCMB.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
