Payment Services, Electronic Money Issuance And Business Models

The Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions (the “Law”) and the Regulation on Payment Services, Electronic Money Issuance and Payment Service Providers, which entered into force in 2021, define under specific headings the payment services that may be provided by payment and electronic money institutions (the “Institutions”) and regulate which activities may be carried out within the scope of a licence. In this regard, it is critical for Institutions to file licence applications that are aligned with their planned business models. This is because determining whether the business model qualifies as a payment service and identifying the relevant licence type for the business model constitute the basis of a properly structured and well-planned compliance process. At this point, the Guide on the Association of Business Models Offered in the Field of Payments with Payment Services (the “Guide”) published by the Central