Turkey

Crypto Licensing

Turkiye's crypto-licensing framework rests on Law No. 7518, which amended Capital Markets Law No. 6362 to require a CMB operating licence for any entity providing crypto-asset trading, custody, transfer, exchange, initial sale or distribution, or listing services targeting Turkish residents. This core requirement is in force and well-established, with a confirmed-tier source behind it, though the precise pinpoint article within Law No. 7518 was not independently confirmed against the Official Gazette text. Operating a CASP without this licence is a criminal offence, reportedly punishable by three to twelve years' imprisonment, a materially severe penalty structure relative to many comparator jurisdictions, though again the exact statutory penalty provision rests on a probable-tier secondary legal source rather than direct Official Gazette confirmation.

The structurally significant development this cycle is the passing of the final transitional deadline. CMB Communique III-35/B.1 established a two-stage process: the transitional cohort of entities already on the CMB's active-entities list had to apply for an operating licence by 30 June 2025, and then obtain full authorisation by 30 June 2026 or face liquidation. That final deadline has now passed, and reporting reaching this cycle, resting on a single source rather than the CMB's own current licence register, suggests that only a small cohort secured full authorisation by the deadline. This is a genuine coverage gap in the evidence rather than a settled finding: the precise population of entities that neither secured licensure nor wound down is not quantified in the material available this cycle, and the CMB's own register would be the authoritative source to resolve it.

Alongside the core licensing requirement, reported minimum capital floors for CASPs sit at TRY 150 million for exchanges and TRY 500 million for custodians, though this figure rests on a single consumer-facing source rather than the CMB's own capital schedule and should be treated as indicative only, at an uncertain confidence tier. A further procedural layer was added in February 2026: a statute amendment to the Turkish Capital Markets Association, effective 27 February 2026, now requires CMB-licensed CASPs to apply for TCMA membership within three months of obtaining their operating permit, and a dedicated CASP professional committee has been established within the TCMA to administer this requirement. This is a probable-tier, well-sourced addition to the compliance stack that layers association membership on top of the core regulatory authorisation, rather than altering the fundamental licensing threshold itself.

Taken together, Turkiye now has a comprehensive, in-force, criminally-backed licensing regime for crypto-asset service providers, but the regime's transitional period has closed with a substantial population of previously-active entities in an unresolved compliance status. This combination, a tightening framework alongside an unresolved transitional cohort, is the defining fact of Turkiye's crypto-licensing position this cycle.

Outlook

The clearest near-term resolution point is whether the CMB publishes or makes public its current, post-deadline licence register; that document would settle the open question of how many transitional-cohort entities secured full authorisation, how many face liquidation, and how many remain in an undefined interim status. Watch also for whether the TCMA membership requirement generates its own secondary compliance friction for newly-licensed entities navigating the three-month post-authorisation window.

Tax Treatment

Turkiye's crypto-asset tax treatment moved on two fronts this cycle, one enacted and narrow, the other proposed and far more consequential, with the latter stalling before enactment. The enacted change is a 0.03% transaction tax applying to crypto-asset buy, sell and transfer transactions conducted through CMB-licensed platforms, approved by the Planning and Budget Committee on 4 to 5 March 2026 and structured as VAT-exempt. This levy is reported as a probable-tier, in-force obligation falling on CMB-licensed crypto-asset service providers, though its final Official Gazette publication and precise enactment date were not independently confirmed beyond the committee-approval reporting. The obligation applies narrowly: it is a transaction-level levy on authorised platforms, not a tax on investor gains or income.

The more consequential proposed reform did not survive this legislative cycle. A 10% quarterly withholding tax on CASP-realised investor gains, together with a progressive income tax of 15 to 40% on withdrawals made through international exchanges, had cleared committee approval as part of a late-2026 omnibus bill before being struck from the final legislation. No crypto-specific income tax is currently in force in Turkiye as a result. Lawmakers have reportedly indicated that the withholding provisions may be reintroduced through separate legislation, with some reporting pointing toward a possible first-quarter-2027 timeframe for reintroduction, though this is an uncertain-tier finding and no formal reintroduction had occurred on the evidence reaching this cycle.

The distinction between these two developments matters structurally. The enacted transaction tax imposes a modest, flat-rate, platform-level compliance burden that CMB-licensed CASPs are already positioned to administer, since it mirrors mechanisms used elsewhere in Turkish financial-transaction taxation. The withdrawn withholding-tax proposal, by contrast, would have required CASPs to function as active tax-withholding intermediaries on investor-level gains, a materially more complex compliance role requiring gain-calculation, cost-basis tracking (reportedly on a FIFO basis) and withholding-remittance infrastructure that does not currently exist in Turkiye's crypto-tax architecture. The gap between what is currently required (a simple transaction levy) and what was proposed but withdrawn (investor-gain withholding) represents the single largest piece of regulatory uncertainty facing Turkish CASPs on the tax front.

Outlook

The item to watch is whether the 10% withholding tax and associated FIFO cost-basis tracking duties return via standalone legislation, with some reporting suggesting a first-quarter-2027 window. If reintroduced, CASPs would need to build investor-level gain-calculation and withholding-remittance capability well beyond their current transaction-tax compliance posture, a substantially larger operational undertaking than the levy currently in force.