Türkiye’s crypto asset market has developed from a largely retail trading environment into a sector with a dedicated framework for service providers. In our experience, the current priority for many businesses is establishing compliant operations, while institutional custody, tokenization and the integration of blockchain into financial infrastructure are receiving increasing attention.

GlobalB Law has worked in crypto asset law since 2017. Our involvement has included organizing a crypto law summit in 2017 and an ICO law summit in 2018, when businesses relied primarily on general legal rules rather than a dedicated crypto asset licensing regime. The absence of sector-specific legislation did not mean that contract, criminal, consumer or tax law ceased to apply.

The regulatory turning points included the introduction of AML obligations for crypto asset service providers and the restriction on using crypto assets in payments in 2021, followed by the 2024 amendments to the Capital Markets Law and the CMB’s 2025 implementing communiqués. We also brought a legal challenge to the payment restriction, which received international media coverage.

Beyond trading, the Digital Turkish Lira project provides a concrete public-sector testing environment for tokenization, programmable payments and interoperability. Supply-chain applications are also being explored: the TARIM2030 program includes work on a blockchain infrastructure platform for agricultural production and traceability. These initiatives should be distinguished from evidence of widespread commercial deployment across all sectors.

Sources: Capital Markets Law Articles 35/B and 35/C; Articles 3–4; Project update; Project evidence; Media coverage

Türkiye regulates the activity and the rights involved, rather than blockchain technology as a single category. Capital Markets Law No. 6362, as amended by Law No. 7518, is the principal statute for crypto asset service providers. Article 3 defines the relevant concepts; Articles 35/B and 35/C establish the authorization, operational, transfer and custody framework. Communiqués III-35/B.1 and III-35/B.2 provide the main implementing rules.

The Capital Markets Board of Türkiye (CMB, or SPK) supervises this framework. MASAK, the Financial Crimes Investigation Board, administers AML and counter-terrorist financing obligations under Law No. 5549 and related legislation. The Central Bank of the Republic of Türkiye (CBRT) regulates payments and electronic money and issued the 2021 crypto asset payment restriction. The Banking Regulation and Supervision Agency has a role where banks provide custody; CMB authorization does not displace the relevant banking requirements.

Other authorities remain important. The Personal Data Protection Authority and Board oversee personal data processing; the Advertising Board oversees consumer advertising; and the Competition Authority and Board address competition issues. Consumer, commercial, contract and criminal law can apply alongside the sector-specific framework.

We expect further regulatory attention to tokenization and the interaction between crypto assets and payments. That is a policy expectation, not an announced entitlement to launch such services. The CBRT already has relevant payments powers; any relaxation of the existing restriction would require an appropriate legal change.

Sources: Articles 3, 35/B(7), 35/C(10); Establishment and operations; Services and capital requirements; Existing payment restriction; Data protection

The policy direction combines support for technological development with close supervision of financial intermediation. The 2030 Industry and Technology Strategy expressly addresses blockchain, decentralized finance (DeFi), crypto assets and real-world asset tokenization. Strategy 32 calls for the technical and legal infrastructure needed for their integration and the development of domestic alternatives. This is a strategic objective, rather than a substitute for an operating permission.

Bank involvement is another sign of institutional interest. The CMB’s provisional list includes banks with custody applications and bank-affiliated market participants. The list itself expressly warns that inclusion does not constitute authorization. It would therefore be inaccurate to treat every listed institution as fully licensed.

In our view, the initial regulatory emphasis on platforms and custody reflects a staged approach to market development. Tokenized instruments and more specialized services may follow as legal and operational arrangements mature. The Digital Turkish Lira project reinforces this direction. At the same time, the continuing payment restriction demonstrates that support for blockchain infrastructure does not imply permission for every crypto asset business model.

Sources: Strategy 32 and paragraphs 75–78; Status of listed institutions; Public-sector development

Yes. The CBRT is developing the Digital Turkish Lira. Its work has progressed beyond the first phase of technical research into a second phase focused on developing and testing the system and its possible uses. The CBRT published a Second Phase Progress Report in November 2025.

The CBRT’s 2026-33 announcement provides a more recent indication of progress. The ecosystem participation process attracted 85 project applications, of which 51 advanced to the second stage and 23 reached the third stage. The third-stage projects cover tokenization, programmable payments, user-sovereign identity, interoperability with existing systems and machine-to-machine payments. Projects can fall within more than one category.

For businesses, the significance is the opportunity to test practical applications and compatibility with financial infrastructure. These project milestones should not be described as confirmation that a retail digital currency has been launched nationwide. The official material reviewed describes development and evaluation, rather than a general public rollout. Nor does participation in the project remove the legal restrictions applicable to private crypto assets.

Sources: Second-phase milestone; 2026 project selection results

Crypto asset services are subject to a dedicated regulatory framework. Article 3(1)(bb) of the Capital Markets Law defines a crypto asset as an intangible asset created and stored electronically using distributed ledger or similar technology, distributed through digital networks and capable of expressing value or rights. The legal treatment of a particular token also depends on the rights it confers. Article 35/B(6), for example, addresses assets providing rights specific to capital market instruments.

There is no comprehensive, standalone Turkish DeFi statute identified in the materials reviewed. This does not create a general exemption. A service must be assessed by its actual functions, the degree of control exercised by identifiable persons and whether those persons provide regulated services. Calling an interface or protocol “decentralized” does not resolve the authorization question.

Self-custody is expressly recognized. Article 35/C(6) states the principle that platform customers hold their crypto assets in their own wallets. Article 24 of Communiqué III-35/B.2 reflects that principle and defines custody services for assets customers choose not to hold themselves. Customers should therefore be able to make an informed choice about custody, subject to lawful transfer controls.

A personal cold wallet and a DeFi protocol are not interchangeable: interacting with a protocol may introduce third-party control, smart-contract risk or a separate financial service. The self-custody principle does not authorize every DeFi activity, eliminate AML requirements or require platforms to integrate with every protocol. In our view, practical support for lawful withdrawals to personal wallets is important to making that principle effective.

Sources: Articles 3(1)(bb), 35/B(6) and 35/C(6); Articles 5–6 and 24; Transfer controls

Crypto asset service providers are obliged entities under the Turkish AML framework. Law No. 5549 requires customer identification under Article 3, suspicious transaction reporting under Article 4, compliance measures under Article 5 and retention of relevant records under Article 8. The requirements extend beyond checking identity: providers must identify beneficial owners, assess risk, monitor activity and maintain an effective compliance organization.

Remote onboarding must satisfy the applicable CMB and MASAK identification rules. It is more than uploading an identity document. The rules address identity-document verification, live interaction or permitted technological methods, security and recordkeeping. The applicable framework allows specified technological methods subject to detailed conditions, so the required process must be assessed for the particular onboarding route. In June 2026, MASAK added Article 4/C to General Communiqué No. 19 to permit passport-based remote identification of eligible foreign individuals and foreign representatives of registered legal entities, subject to its conditions.

The travel rule is addressed in Article 24/A of the AML Measures Regulation. MASAK General Communiqué No. 29 adds enhanced transfer measures. As explained in MASAK’s compliance guide, specified withdrawals involving unhosted wallets or foreign institutions without corresponding information-sharing obligations are subject to minimum waiting periods of 48 hours, or 72 hours for the first withdrawal. Stablecoin withdrawals are subject to daily and monthly limits, with conditional adjustments and exceptions. These are not universal limits on all trading or all wallet activity.

Suspicious transaction reports can be submitted through MASAK Online. Providers must also comply with applicable asset-freezing measures under Laws Nos. 6415 and 7262. For DeFi, the analysis turns on the persons and services involved; use of an unhosted wallet does not remove sanctions or criminal-law exposure. We regard the operational burden as substantial, requiring sustained investment in personnel, procedures and technology.

Sources: Law No. 5549; travel rule, enhanced measures and sanctions; Remote identification framework; Communiqué No. 32 and new Article 4/C; Electronic reporting

The absence of a comprehensive, settled crypto-specific tax framework should not be confused with an exemption from existing taxes. Platforms are businesses, and their taxable profits remain subject to the ordinary rules. Corporate Tax Law No. 5520, Article 6, governs the determination of corporate profits; Income Tax Law No. 193, Article 37, addresses commercial income. The tax analysis therefore differs between a platform’s service revenue, a business’s trading activity and an individual’s investment transactions.

In March 2026, Parliament considered proposals for crypto asset transaction taxation and a specific income-tax mechanism. The plenary record confirms that the relevant crypto tax provisions were removed from that bill for reconsideration. The proposed transaction tax and the associated VAT exemption should consequently not be described as having entered into force through that proposal. Withdrawal of those provisions does not establish that every existing tax is inapplicable.

For an individual or a DeFi participant, classification, residence, the commercial character of the activity and the nature of the receipt remain important. Token sales, staking rewards, lending returns and transfers between a person’s own wallets should not automatically be treated as identical taxable events. Uncertain classifications call for transaction-specific tax analysis rather than a categorical assurance of tax-free treatment.

Separately, Capital Markets Law Article 130(5) requires platforms to pay 1% of their preceding year’s revenue, excluding interest income, to the CMB and a further 1% to TÜBİTAK. These statutory contributions must be distinguished from taxes on investors’ gains.

Sources: Corporate Tax Law Article 6; Income Tax Law Article 37; Removal of proposed crypto tax provisions; Article 130(5)

In our practice, the focus has shifted from predominantly entrepreneurial token projects toward more structured institutional initiatives. Regulated custody and greater engagement by established financial institutions support that shift, although legal uncertainty can still slow implementation. The 2030 strategy’s explicit reference to real-world asset tokenization is encouraging, but it does not itself authorize a product.

A tokenization project should begin with the underlying legal rights. A token representing a share, debt claim, ownership interest or right to income requires a different analysis from a token used solely to access a service. Capital Markets Law Article 13 permits the CMB to establish rules for issuing capital market instruments as crypto assets; Article 35/B(6) addresses tokens conferring rights specific to those instruments.

Communiqué III-35/B.2, Article 16, requires platforms involved in initial sales or distributions to examine relevant smart-contract elements and compliance with the rules governing the asset. Article 16(4) is particularly important where another regulator’s jurisdiction is engaged. Creating a token does not, by itself, transfer legal title to an underlying asset or satisfy any registration or formality that the underlying transaction requires.

Retail and institutional projects therefore need clear documentation of ownership, redemption, transfer restrictions, custody, insolvency treatment and investor eligibility. Institutional participation may improve execution and governance; it does not remove the need to classify the product and obtain any required permissions.

Sources: Articles 13 and 35/B(6); Article 16; Tokenization policy

Türkiye does not impose a general prohibition on owning or trading crypto assets. Individuals and companies can hold and trade them, subject to the laws applicable to the transaction and the investor. Professional provision of platform or custody services is a separate matter and requires compliance with the CMB framework. A company trading for its own account should not be confused with a business offering services to customers.

Access to foreign providers requires a careful distinction. Article 9 of Communiqué III-35/B.2 excludes services obtained entirely on a Turkish resident’s own initiative where the foreign provider does not promote or market its services to residents in Türkiye. A foreign provider’s Turkish-language website, local establishment or directed marketing can bring its activities within the Turkish regime. This is not an unrestricted right for foreign platforms to solicit Turkish customers.

Foreign customers can use Turkish platforms subject to lawful onboarding and applicable restrictions. The 2026 passport-based remote identification development facilitates eligible onboarding; it should not be described as the first general legalization of foreign investment. Proprietary arbitrage is not categorically prohibited, but repeated intermediation for others may raise licensing and AML questions.

The principal restrictions include direct or indirect use of crypto assets in payments under Articles 3–4 of the CBRT regulation. Article 14 of Communiqué III-35/B.2 prohibits leveraged trading, derivatives and specified margin, short-selling and lending transactions involving assets listed on regulated platforms. Article 30 of Communiqué III-35/B.1 restricts misleading promotions, return promises and campaigns rewarding customer referrals; the referral restriction is broader than influencer arrangements alone.

Token issuance and NFT activities cannot be characterized as universally permission-free. Their treatment depends on the rights, services and distribution model. In our experience, retail trading remains a prominent part of the market, but we do not equate that observation with a verified national adoption percentage.

Sources: Articles 6, 7–9 and 14; Article 30; Articles 3–4; Foreign-customer remote identification

The early ICO market developed before Türkiye had a dedicated crypto asset service provider regime. Our 2018 ICO law summit reflected the need to analyze token projects using general legal principles at that stage. Today, the absence of a single statute labeled an “ICO law” does not make token fundraising unrestricted.

The starting point is the substance of the token and the offer. Rights resembling those of capital market instruments engage Article 35/B(6) of the Capital Markets Law and potentially the relevant issuance framework. Article 13 also empowers the CMB to regulate the issuance of capital market instruments as crypto assets. A platform’s internal approval cannot replace an approval or authorization required by law.

For initial sales or distributions through platforms, Communiqué III-35/B.2, Article 16, imposes smart-contract and legal-compliance checks. Articles 20–22 govern the listing committee, eligibility criteria and written listing procedures. The board establishes the committee and approves the procedure; the committee assesses individual listings. This allocation of responsibilities is more precise than saying that issuance is permitted whenever a platform’s board agrees.

The communiqué treats specified unique, non-fungible assets and assets used solely within virtual games separately in Articles 7–8, with a listing-rule exclusion in Article 21(3). Those provisions do not create a general exemption for every token described as an NFT, gaming token or utility token. Nor does the absence of platform trading conclusively resolve the position of a direct offering. Issuers should assess the actual rights, target investors, marketing, custody and transfer arrangements before launch.

Sources: Articles 13 and 35/B(6)–(8); Articles 7–8, 16 and 20–22

Crypto assets can form part of a person’s economic estate, but private-key control, a platform account balance and legal ownership are different concepts. An on-chain transfer may be evidence of a transaction without resolving authority, mistake, fraud or competing ownership claims. The applicable contract and the legal nature of the asset remain relevant.

General succession principles provide a basis for including crypto assets in an estate. Civil Code Article 599 provides for the acquisition of an estate by heirs. Practical recovery nevertheless depends on identifying the assets and obtaining lawful access to the relevant wallet or custodian. An inheritance plan should address access without unnecessarily exposing private keys.

Crypto assets may also be relevant to matrimonial property proceedings. Under the statutory participation regime, Articles 219–220 distinguish acquired property from personal property, including inherited assets. The acquisition date, source of funds and applicable property regime matter; a wallet balance is not automatically divided equally. In enforcement proceedings, identifying the asset and the person or provider capable of complying with an order is often decisive. Self-custody can make execution more difficult than attachment of a conventional bank account.

Security arrangements require particular care. Capital Markets Law Article 35/B(10) expressly excludes crypto asset pledge agreements from Law No. 6750 on movable pledges in commercial transactions. A contractual or technical lock-up should not automatically be described as a perfected pledge enforceable against third parties. Priority, control, insolvency and enforcement need separate analysis. Article 35/C(7) also separates customer assets from the provider’s estate and protects them against the provider’s creditors; it does not create blanket immunity from the customer’s own creditors.

Sources: Articles 219–220 and 599; Articles 35/B(10) and 35/C(7)

Türkiye has no generally applicable statutory category that makes a smart contract valid solely because it runs on a blockchain. A smart contract may implement a legally enforceable agreement, form part of one or simply execute a technical instruction. The distinction depends on the facts.

Under Code of Obligations No. 6098, Article 1, a contract requires corresponding expressions of intent. Article 12 preserves statutory form requirements, while Articles 26–27 address contractual freedom and its limits. Automated execution does not cure lack of authority, illegality or failure to satisfy a mandatory formality. A wallet signature should not automatically be equated with every form of legally recognized signature.

Documentation should explain the relationship between the written terms and the code, the treatment of errors and external data feeds, upgrade powers, applicable law and dispute resolution. The technical irreversibility of a transfer does not necessarily extinguish a legal claim for restitution or damages, although recovery may be difficult.

There are already sector-specific rules involving smart contracts. Article 16 of Communiqué III-35/B.2 requires relevant checks where a platform intermediates an initial sale or distribution. Accordingly, the accurate position is that there is no comprehensive general smart-contract statute, rather than no legal recognition of smart contracts at all.

Sources: Articles 1, 12 and 26–27; Article 16

A decentralized autonomous organization does not acquire separate legal personality or limited liability in Türkiye merely by deploying code or issuing governance tokens. No dedicated Turkish DAO legal form was identified in the legislation reviewed. A DAO’s structure must therefore be assessed under existing rules.

One possible characterization is an ordinary partnership under Code of Obligations Article 620, where two or more persons agree to combine their labor or assets for a common purpose and the arrangement does not have the defining characteristics of another recognized entity. That is a fact-specific analysis: passive token ownership alone should not automatically be treated as proof of partnership.

The consequences can be significant. Article 638 addresses jointly held partnership assets and, unless otherwise agreed, joint and several liability for obligations undertaken together or through a representative within the partnership relationship. Identifying members, authority and the applicable law can be difficult in an international structure.

Participants should document decision-making powers, treasury control, representation, exits and dispute resolution. Where appropriate, a recognized legal entity can provide a clearer contractual interface. It does not, however, remove licensing obligations if the underlying activity constitutes a regulated crypto asset or financial service.

Sources: Articles 620 and 638; Articles 5–6

Yes. Crypto asset businesses face several distinct forms of supervision and enforcement. The CMB can address unlawful or unauthorized activity under Capital Markets Law Articles 99/A and 99/B, while Article 109/A criminalizes unauthorized crypto asset service provision. The legal basis and procedure differ from those for an ordinary commercial dispute.

MASAK compliance failures can result in administrative sanctions under Law No. 5549. Advertising is also an active enforcement area: Advertising Board Bulletin 367 records decisions concerning crypto platform advertising, including unsubstantiated leadership claims. These decisions illustrate why marketing review must extend beyond a platform’s terms and conditions.

Suspected fraud, laundering or misappropriation can lead to criminal investigations and legally authorized measures affecting assets or company management. Asset freezing under sanctions legislation, temporary postponement of a transaction under the AML framework and seizure in criminal proceedings are different mechanisms. It would be inaccurate to suggest that every allegation allows a prosecutor to freeze any asset without the relevant statutory conditions and judicial controls.

From a practical perspective, businesses need reliable transaction records, escalation procedures and access to both regulatory and litigation expertise. An investigation, provisional measure or administrative finding should not be described as a final criminal conviction. Similarly, restrictions on customer onboarding or appointment of a trustee should only be attributed to a particular company where the underlying decision has been verified.

Sources: Articles 99/A, 99/B and 109/A; Law No. 5549 and sanctions framework; Verified advertising enforcement examples

Personal Data Protection Law No. 6698 is particularly important because information on a blockchain may remain personal data when it can be linked to an identifiable individual. Articles 4–6 address processing principles and legal conditions; Article 7 addresses erasure, destruction and anonymization; Article 9 governs international transfers; and Article 12 requires security measures. A public ledger’s permanence and international replication can complicate compliance. Hashing or pseudonymization does not necessarily make information anonymous.

In our view, projects should minimize personal data stored on-chain and consider keeping identifiable material off-chain under controlled access. That design choice is not a legal exemption: the remaining identifiers, metadata and cross-border flows still require assessment.

In insolvency, Article 35/C(7) of the Capital Markets Law requires separation of customer cash and crypto assets from a provider’s assets and excludes customer property from enforcement for the provider’s debts. This protection should not be confused with a state guarantee. Article 35/C(4) excludes crypto assets from the law’s investor-compensation provisions, and Article 35/C(6) excludes the relevant assets and customer cash from the deposit-insurance provisions specified there.

General consumer, competition, intellectual property and contract rules also remain relevant. Our policy concern is that the payment restriction limits the space for some innovative business models, while restrictions on leveraged products may encourage some customers to seek foreign services. These are professional assessments of possible market effects, rather than proven causal findings. Judicial remedies and liability continue to depend on the facts and the applicable procedural law.

Sources: Articles 4–7, 9 and 12; Article 35/C(4), (6) and (7); Articles 3–4; Article 14

Effective advice in this field requires more than corporate structuring. Lawyers need to understand how platforms, wallets, custody arrangements and blockchain transactions operate, and how those arrangements behave when a dispute, investigation or operational failure occurs. Litigation and criminal-law experience are particularly valuable when advising on account restrictions, disputed transfers, asset recovery and management exposure.

The first task is to map the actual business model: who controls the assets, who executes transfers, which rights the token represents, who is being approached in Türkiye and which entity contracts with the customer. Labels such as “technology provider,” “non-custodial” or “utility token” cannot replace that analysis.

Counsel must also distinguish an application or provisional-list entry from authorization and track changes to transitional arrangements. The CMB’s March 26, 2026 decision tied the determination of specified custody-agreement and authorization deadlines to the widespread availability of authorized custody services. A historical timetable is therefore not a reliable substitute for checking the latest decision and the provider’s own position.

We also recommend working closely with compliance and technical teams throughout product development. Understanding wallet permissions, transaction records, incident response and customer communications makes legal advice more useful in practice. Continuing professional experience and practical technological learning are both essential in a market where the legal framework and the products continue to develop.

Sources: Provisional listing is not authorization; Decision 18/617, page 6; Governance and operational requirements