Open Banking In Turkey: What's The Status?

1. Introduction

There have been various legal developments in Turkey with regards to 'open banking' since the beginning of 2020.

First, the an amendment on the Law on Payment and Securities Settlement Systems, Payment Systems and Electronic Money Institutions numbered 6493 ("Payment Law") has become effective as of 1 January, which defined account information services (AIS) and payment initiation services (PIS) for the first time under Turkish payment regulations. Although the Payment Law does not explicitly mention 'open banking' services, the services that are offered within the meaning of 'open banking' in PSD2 are regulated under Payment Law.

Then, 'open banking' services have been explicitly defined another banking related regulation; Regulation on the Information System of Banks and Electronic Banking Services ("Banking Regulation"). The definition therein is as follows: