One of the most important issues faced by investors wishing to establish a payment institution in Turkey is the minimum capital requirement. However, for payment institutions, it is not sufficient to only look at the capital that the company must have at the time of establishment. In the legislation, paid-in capital, minimum equity , and in some cases, collateral obligations are regulated as different financial adequacy conditions.

This distinction is particularly important in fintech investments. For example, the fact that the legislation stipulates an initial capital of 2,000,000 TL for a specific payment institution does not mean that the company can operate with a capital of 2,000,000 TL and obtain a license from the Central Bank of Turkey (TCMB). This is because the minimum equity amounts required for payment institutions in 2026 have significantly exceeded the initial capital requirement.

In Turkey, the establishment and operation of payment institutions are primarily Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions, and the Regulation on Payment Services, Electronic Money Issuance and Payment Service Providers .

This article details the following questions: What is the minimum capital requirement for payment institutions? What are the capital requirements for payment institutions according to the Central Bank of Turkey (TCMB)? What is the minimum equity capital requirement for payment institutions? And how much capital is actually needed to establish a payment institution ?

Are there capital requirements to establish a payment processing company?

Yes. In Türkiye, companies wishing to operate as payment institutions are required to have a certain level of financial capacity.

This financial adequacy is not limited solely to the capital the company possessed on the date of its registration in the commercial registry.

From the perspective of payment institutions, three main concepts need to be distinguished from each other:

1. Initial or paid-in capital
2. Minimum equity
3. Collateral and other financial obligations

Confusing these three concepts can lead to a serious miscalculation of the true cost of payment institution investment.

What is the minimum paid-in capital for payment institutions?

The initial capital required for payment institutions varies depending on the nature of the payment service to be offered.

Basically, within the framework of the current regulations;

• a minimum balance of 1,000,000 TL,
• payment institutions established to provide other payment services have a minimum capital of 2,000,000 TL.

There is a paid-up capital requirement.

For organizations that exclusively provide accounting information services, there are specific regulations and exceptions in the legislation.

The amounts here relate to the company's initial capital .

Therefore, the statement "a payment institution can be established with a capital of 2 million TL" can be misleading when used alone.

This is because, in addition to initial capital, payment institutions are required to meet much higher minimum equity requirements .

What is the minimum equity requirement for payment institutions in 2026?

As of 2026, one of the most important financial criteria for payment institution investment is the minimum equity requirement.

The minimum equity capital requirements for payment and electronic money institutions have been redefined, effective from June 30, 2026

Accordingly;

Type of organization	Minimum equity
A payment agency that only facilitates bill payments	20,000,000 TL
Other payment institutions, excluding those exclusively providing account information services	40,000,000 TL
Electronic money institution	105,000,000 TL

Therefore, when preparing an investment plan for a payment institution that will offer payment services such as money transfer, acceptance of payment instruments, or similar services, a minimum equity level of 40 million TL should be taken into consideration.

Electronic money institutions, however, are in a separate licensing category, and therefore , a minimum equity capital requirement of 105 million TL will apply to them in 2026

What is the difference between capital and equity?

This is the most confusing issue in payment processing facilities.

Capitalrefers to the value stated in the company's articles of association and committed or paid into the company by its shareholders.

Equity, on the other hand, is a broader concept that reflects a company's financial condition.

Company capital is a part of equity; however, equity does not consist solely of capital.

For example;

• paid-in capital
• capital reserves,
• profit reserves,
• past results,
• period profit or loss

Various items, such as these, can affect equity.

Therefore, the fact that the company's articles of association state a capital of 2 million TL does not mean that the company has the 40 million TL equity required by the legislation.

When financially planning an investment in a payment processing facility, these two conditions should be evaluated separately.

Is it possible to obtain a Payment Institution License with a capital of 2 million TL?

In practice, this is one of the most frequently asked questions by investors.

Although the legislation initially stipulates a paid-in capital of 2 million TL for certain payment institutions , it is not possible to say that all financial adequacy requirements of a payment institution are met with this amount alone as of 2026

Because other payment institutions have a minimum equity level 40 million TL .

Therefore, the company merely meeting its legal initial capital requirement does not automatically mean it has fulfilled the financial adequacy criteria for obtaining an operating license from the Central Bank of Turkey (TCMB).

When planning a fintech investment, not only the "capital required to start the company" but also the total financial structure necessary to obtain and maintain the operating license should be considered.

Are the capital requirements different for bill payment institutions?

Yes.

A different financial structure has been envisioned for payment institutions that will only provide intermediary services for bill payments.

While an initial capital of 1 million TL is foreseen for these institutions , the minimum equity level will be applied as 20 million TL from June 30, 2026

However, the important point here is that it offers "exclusive" bill payment services.

If the company also wants to offer different payment services, stricter financial eligibility requirements may come into play.

Therefore, it is not sufficient for a payment institution to simply narrow its scope of activity in its articles of association in order to benefit from lower capital or equity requirements. The actual business model and the services to be offered must be defined in accordance with the legislation.

Do organizations providing financial information services have capital requirements?

Account information services have features that differentiate them from classic payment services.

In this service, the organization primarily acts as an intermediary in compiling and presenting information online regarding the user's accounts with different payment service providers.

For organizations exclusively providing accounting information services, there are specific exceptions in the legislation regarding initial capital and minimum equity.

Therefore, it may not be appropriate for companies wishing to operate in the open banking sector to directly apply the capital requirements of a standard payment institution to their own business models.

First, it should be assessed whether the service offered truly falls within the scope of solely providing account information.

Are the Payment Order Initiation Service and the Account Information Service the same?

No.

In fintech and open banking projects, these two activities are often confused with each other.

The account information serviceallows a customer to view or aggregate financial information from their various accounts.

The payment order initiation service is a service that allows a customer to initiate a payment transaction from their payment account with another payment service provider.

The fact that the legal nature of the two services differs may necessitate a different assessment of licensing and financial adequacy requirements.

Therefore, the specific services that the open banking initiative will offer must be clearly defined before the license application.

Should the minimum equity requirement only be met when obtaining a license?

No.

The minimum equity requirement is not merely a temporary financial adequacy requirement that can be shown only when obtaining the Central Bank of Turkey's operating license and then removed later.

The payment institution must maintain the financial adequacy specified in the legislation throughout its period of operation.

Therefore, the company;

• to incur losses,
• increased operational costs,
• growth in past year's losses,
• loss of a large amount of capital

Situations like these can reduce equity levels.

Therefore, the payment institution needs to not only contribute capital during the licensing phase but also monitor its capital adequacy and equity level throughout its operations.

Does the need for equity increase as transaction volume increases?

It may increase.

In payment institutions, equity requirements are not limited to a fixed minimum amount.

Depending on the type of activity and payment volume of the organization, equity can also be calculated using the methods specified in the legislation.

In this case, the equity that the payment institution is required to hold may exceed the fixed minimum amount.

For example, even if a company meets the minimum equity level stipulated by legislation during the initial stages of its operations, a need for additional capital may arise when its transaction volume grows significantly.

Therefore, for payment institutions aiming for rapid growth, capital planning should not be based solely on the date the license is obtained.

Future equity requirements should also be anticipated based on three- or five-year trading volume projections.

Could the Central Bank of Turkey (TCMB) Demand Higher Equity Capital?

Payment institutions have different risk profiles.

Transaction volume, number of customers, business model, operational structure, and risks encountered are important factors in evaluating an organization's financial adequacy.

It is also possible for the Central Bank of Turkey (TCMB) to apply a certain degree of increase to the equity requirement calculated as a result of its assessment within the scope of the legislation.

Therefore, minimum equity requirements should not be viewed as a fixed investment cost that cannot be exceeded under any circumstances for any company.

The actual capital requirements of a payment institution;

license scope + transaction volume + number of customers + operational expenses + technical investment + risk profile

They should be determined by evaluating them together.

How Should the Payment Institution's Capital Be Paid?

In payment institutions, it's not just the amount of capital that matters.

The nature and source of capital are also important in the CBRT's investigation.

The payment institution must have its capital, as stipulated by law, paid in cash and free from any form of collusion

In other words, simply showing capital on the balance sheet is not enough.

The funds contributed by the partners to the company must be genuine, and the source of the capital must be explainable.

At this point in particular;

• the financial strength of the partners,
• where the money was obtained from,
• whether the capital was obtained through borrowing,
• The source of funds coming from abroad,
• money transfers between companies,
• who the real beneficiaries are

This could become important in the Central Bank of Turkey's license review process.

Why is the Source of Capital Important?

Payment institutions are financial institutions that act as intermediaries in the transfer of customers' funds.

Therefore, from the licensing authority's point of view, simply "having the money available" is not enough.

The capital must be legally valid, explainable, and demonstrated to have originated from the genuine economic resources of the partners.

Especially in companies with foreign partnerships;

The foreign partner may require more comprehensive documentation including financial statements, company documents, business history, ultimate beneficiaries, and the process of transferring capital to Türkiye.

Therefore, instead of investors trying to raise capital just before applying for a license, it is important for them to plan the financing structure at the beginning of the project.

Could a capital increase be necessary for payment institutions?

Yes.

A capital increase may be necessary if the company's equity level falls below the amount required by legislation or if its operating volume increases.

In addition, the payment institution;

• launching a new payment service
• expanding its field of activity,
• experiencing rapid customer growth,
• incurring major operational losses

In this case, the existing capital structure needs to be re-evaluated.

Therefore, capital increases in payment institutions are not merely a company law transaction under the Turkish Commercial Code.

Capital changes also have consequences in terms of Law No. 6493 and Central Bank of Turkey regulations .

What Risks Does Capital Loss Pose for Payment Institutions?

If a payment institution incurs losses and its equity falls below the level required by legislation, this can pose a significant regulatory risk.

In this case, not only the provisions regarding capital loss under the Turkish Commercial Code but also the financial adequacy provisions specific to payment institutions come into play.

If the institution fails to maintain the required capital and equity conditions, the Central Bank of Turkey (TCMB) may take action;

It is possible that the deficiency will be requested to be remedied, various measures will be implemented, activities will be restricted, or sanctions regarding the operating license will be considered in case of serious violations.

Therefore, it is important for payment institutions to have monthly or periodic financial reporting systems that can detect changes in equity levels at an early stage.

Are Payment Institution Capital and Customer Funds the Same Thing?

No.

This distinction is extremely important.

The payment institution's company capital and equity are the institution's own assets.

Payment funds transferred by customers to the organization for the purpose of processing payments are not working capital that the company can freely use .

Customer funds must be separated and protected from the organization's other funds using methods prescribed by law.

Therefore, funds held by customers in their payment institution accounts or transferred to the company as part of payment transactions cannot be used to meet the company's minimum capital or equity requirements.

Can the capital requirement be met with customer funds?

No.

It is not possible to use customer funds as if they were the capital of the payment institution.

The payment institution's equity and capital requirements from its own financial resources .

This is one of the fundamental security mechanisms for protecting customers' funds in the event of the payment institution's bankruptcy or financial difficulties.

Do Payment Institutions Require Collateral?

The financial responsibilities of payment institutions are not limited solely to capital and equity.

Depending on the nature of the activity and the organization, collateral obligations may also arise.

The purpose of the collateral is to provide additional financial security against certain risks that may arise from the payment institution's operations.

Therefore, when an investor calculates the establishment cost of a payment institution, they only need to consider:

"40 million TL in equity is required."

One should not perform calculations in this manner.

The company's technical infrastructure, personnel, independent audits, application fees, license fees, guarantees, and operating capital requirements should also be taken into account.

What is the actual capital requirement for establishing a payment processing company?

It is not accurate to give a single figure for all payment institutions in response to this question.

For example, the fact that a minimum equity level of 40 million TL is applied to other payment institutions in 2026 does not mean that the entire investment of a payment institution can be completed with a budget of 40 million TL.

In addition to this, the company;

• personnel expenses,
• executive salaries,
• software development expenses,
• information systems infrastructure
• server and data infrastructure,
• cybersecurity investments,
• independent audit expenses,
• legal and compliance expenses
• bank integrations,
• rent and office expenses,
• Central Bank of Turkey application and licensing fees,
• working capital needs that will arise during the operation period

will be found.

Therefore, when preparing the actual investment budget, it may be necessary to exceed the minimum figure stipulated in the legislation.

Why are the capital requirements for electronic money institutions higher?

Electronic money institutions and payment institutions do not have the same type of license.

Electronic money institutions are subject to a different legal and financial regime than those that can issue electronic money.

Another significant consequence of this distinction is that the minimum equity capital for electronic money institutions will be 105 million TL by 2026

Therefore, in a business model where customers deposit money and receive a digital balance in return, it may not be appropriate to create a 40 million TL equity account by saying "we will establish a payment institution".

If the business model involves the issuance of electronic money, different licensing and capital requirements will apply.

Are the capital requirements different for payment institutions with foreign partners?

As a rule, capital and equity requirements do not automatically differ simply because a company has foreign partners.

However, the foreign partnership structure may affect the scope of the license review.

From the perspective of the Central Bank of Turkey (TCMB);

• the financial strength of the foreign company,
• company's operational history,
• partnership chain,
• the ultimate beneficiary,
• source of capital,
• transfer of funds to Türkiye

Issues such as these need to be clarified.

In multi-layered international holding companies, determining the true control owner and the source of capital may require a more comprehensive study.

How should capital planning be done before obtaining a Payment Institution License?

Investors wishing to establish a payment processing institution would benefit from a three-stage capital planning approach.

First, which type of license is required .

Secondly, the initial capital, minimum equity, and other financial obligations must be calculated.

Thirdly, an additional financial reserve should be created to cover the operational expenses and potential losses that the company will face in the first few years after obtaining its license.

For example, if a company starts operations exactly at the minimum equity limit, there is a risk that its equity may fall below the legal level in a short time due to initial operating losses.

Therefore, in practice, creating a financial buffer above the minimum amount may be important.

The Most Common Mistakes Regarding Minimum Capital Requirements in Payment Institutions

The main mistakes regarding financial planning in payment institution investments are as follows:

• Assuming that the initial capital and the minimum equity are the same,
• The belief that only 1 or 2 million TL of capital is sufficient,
• Failure to consider current equity figures in effect in 2026,
• treating customer funds as company capital,
• Failure to take into account that operating expenses can reduce equity,
• Ignoring the fact that additional equity needs may arise when trading volume increases,
• confusing the financial terms of electronic money institutions with those of payment institutions,
• Failure to document the source of capital from the outset,
• Technical and operational establishment costs should not be included in the investment budget.

These errors could render the investment project financially unfeasible even before obtaining the operating license from the Central Bank of Turkey (TCMB).

Should a financial and legal feasibility study be conducted before establishing a payment processing institution?

The first step in the payment processing project is not simply to establish a limited liability company.

Firstly;

Business model → License type → Capital requirement → Equity requirement → Technical requirements → Total investment budget

A comprehensive feasibility study needs to be conducted, following a specific order.

In particular, the distinction between a payment institution and an electronic money institution can significantly alter the investment amount.

Similarly, the financial responsibilities of an organization that only facilitates bill payments are not the same as those of a fintech company that will offer comprehensive payment services.

Therefore, it is important to legally evaluate the business model under Law No. 6493 before the company is established, contracts are signed with investors, and the software development process begins.

Frequently Asked Questions

How much capital in Turkish Lira will a payment processing institution need in 2026?

While the legislation initially stipulated paid-in capital requirements of 1 million TL or 2 million TL depending on the type of activity, these figures alone are insufficient. As of June 30, 2026, payment institutions that only act as intermediaries for invoice payments of 20 million TL, while other payment institutions should, as a rule, a minimum equity level of 40 million TL .

Is investing 40 million TL sufficient for a payment processing facility?

Not in every case. The 40 million TL minimum equity level does not represent the total cost of the investment. Technical infrastructure, personnel, collateral, independent audit, application and licensing expenses, and working capital should be evaluated separately.

Are minimum capital and minimum equity the same thing?

No. Capital is one of the items included within equity. Equity provides a broader overview of a company's financial situation.

Can the payment institution's capital be reduced at a later date?

Capital and equity changes are not evaluated solely under the Turkish Commercial Code for payment institutions. Regulations of the Central Bank of the Republic of Turkey (TCMB) and minimum financial adequacy requirements must also be maintained.

What is the minimum equity capital required for an electronic money institution?

As of June 30, 2026, the minimum equity capital requirement for electronic money institutions 105 million TL .

How much capital is needed for a virtual POS company?

“Virtual POS” is a commercial designation. The amount of capital required cannot be determined solely based on the term “virtual POS” without examining the company's legal role in the payment chain and the payment services it offers. The business model must first be classified under Law No. 6493.

Conclusion: Looking only at initial capital is not enough when it comes to payment institutions

One of the biggest misconceptions of investors who want to establish a payment institution in Türkiye is that they consider the initial capital specified in the legislation as the total capital requirement of the project.

However, minimum capital requirements for payment institutions , initial capital, minimum equity, financial adequacy based on transaction volume, collateral, and working capital needs should be considered together.

The requirement of a minimum equity level of 20 million TL for payment institutions that only facilitate bill payments and 40 million TL for other payment institutions as of 2026 indicates that payment institution investments require a much more comprehensive financing need than just initial capital.

The requirement for a minimum equity capital of 105 million TL for electronic money institutions by 2026 demonstrates that the legal distinction between a payment institution and an electronic money institution directly impacts the financial scale of the investment.

Therefore, for entrepreneurs who want to obtain a Central Bank of Turkey (TCMB) payment institution licenseto evaluate their business model, the required license type, current capital and equity requirements, and future financing needs together before establishing their company.