ARTICLE
7 April 2025

Developments In Open Banking And Digital Wallets

EA
Esin Attorney Partnership

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Esin Attorney Partnership, a member firm of Baker & McKenzie International, has long been a leading provider of legal services in the Turkish market. We have a total of nearly 140 staff, including over 90 lawyers, serving some of the largest Turkish and multinational corporations. Our clients benefit from on-the-ground assistance that reflects a deep understanding of the country's legal, regulatory and commercial practices, while also having access to the full-service, international and foreign law advice of the world's leading global law firm. We help our clients capture and optimize opportunities in Turkey's dynamic market, including the key growth areas of mergers and acquisitions, infrastructure development, private equity and real estate. In addition, we are one of the few firms that can offer services in areas such as compliance, tax, employment, and competition law — vital for companies doing business in Turkey.
The Regulation Amending the Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers (the "Regulation"), prepared by the Central Bank of the Republic of Türkiye...
Turkey Finance and Banking

Recent Developments

The Regulation Amending the Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers (the "Regulation"), prepared by the Central Bank of the Republic of Türkiye (the "CBRT"), was published in the Official Gazette on March 28, 2025 (the "Amending Regulation"). You can access the Amending Regulation here.

What's New?

Developments in Open Banking

Under the Regulation, all payment service providers holding payment accounts that may be related to payment-initiation and account information services, which are considered among open banking products, were required to connect to Bankalararası Kart Merkezi A.Ş., and to provide the required systems and support to all other authorized payment service providers that requested the offering of open banking services related to these accounts, and to take necessary measures to prevent unauthorized provision of open banking services by March 31, 2025.

According to the Amendment Regulation, all payment service providers holding payment accounts that may be related to open banking services will no longer be required to comply with these regulations. Instead, payment service providers that hold these payment accounts and also provide their clients with direct online access to payment accounts will be subject to these regulations. Therefore, payment service providers that do not provide their clients with direct online access will not be subject to these obligations.

The Amendment Regulation also stipulates that a payment service provider must be a participant in the Instant and Continuous Transfer of Funds System ("FAST") to be subject to these obligations.

For institutions that are not participants in FAST, those that are among the top ten institutions in terms of payment volume, calculated based on transactions from the previous calendar year, will be subject to these obligations.

Under the Amendment Regulation, the deadline for compliance with these obligations has been extended to December 31, 2025.

Digital Wallet Regulations Compliance Deadline Extended Again

On October 7, 2023, the amendment to the Regulation introduced important provisions for the use and promotion of the digital wallet service in the field of payments. According to the amendment, it was stipulated that (i) persons offering digital wallet services without an operating license before this date were required to apply to the CBRT to obtain the necessary licenses, and (ii) payment service providers offering digital wallet services were required to comply with the introduced regulations.

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.

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