Non-passporting licence routeCASP authorisationNo passporting

CASP Authorisation in Turkey

Turkey is a local-market CASP route with no EU/EEA passporting. It fits teams targeting Turkish crypto asset services and able to support high capital, local substance and regulator-facing operations.

Processing time
From 3 months
Service price
52 800 EUR
Required share capital
From 1 300 000 EUR
State fee
On an individual basis
Annual supervision fee
On an individual basis
Banking difficulty
High
RegulatorSermaye Piyasası Kurulu
Market access
No passporting

What is Turkey CASP authorisation?

Turkey CASP authorisation is a local crypto asset service provider route under the Turkish capital markets framework. It should be used for Turkey-facing regulated crypto asset services, not as an EU MiCA passporting substitute.

CASP
Jurisdiction
Turkey
Regulator
Sermaye Piyasası Kurulu
Regime
CASP
Legal basis
Legal basis: Turkish CMB/SPK crypto asset service provider framework.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Turkey CASP service scope

Define whether the project is an exchange, custody, wallet, brokerage or platform-style CASP before discussing timing or cost. Broad scope increases capital, governance, AML and technology burden.

  • Exchange

    Conditional

    Exchange activity may require additional scope or separate licensing.

  • Custody

    Conditional

    Custody may require separate review or additional controls.

  • Brokerage

    Conditional

    Brokerage or OTC activity typically fits within scope.

  • Wallet provider

    Conditional

    Exchange activity may require additional scope or separate licensing.

  • EU market

    Excluded

    EU passporting not available from this route.

  • Startups

    Excluded

    High setup complexity means significant budget is needed.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Turkey local market access conditions

Turkey is primarily a local-market route. Market access should be tested against Turkish client targeting, regulator-facing operations, banking and local substance, not against EU passporting expectations.

  • Target market and Turkish client onboarding must be explicit.

  • Local staff, office, governance and audit expectations should be budgeted from the start.

  • No EU/EEA passporting should be implied from Turkey CASP authorisation.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Turkey CASP capital and governance profile

Turkey CASP is capital-heavy compared with many registration routes. A strong file documents capital adequacy, accountable management, local compliance and technology controls before submission.

  • High capital requirement must match activity scope and operating risk.high
  • Local governance should identify accountable directors, compliance and operations owners.high
  • Audit, AML, custody and technology controls need to be documented as operating obligations.high

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Turkey CASP application bottlenecks

Typical blockers are not form-filling issues; they are capital, governance, custody, banking and scope problems that make the operating model hard to approve or maintain.

  • Undercapitalised setup for the intended CASP activity

    High
  • Unclear distinction between Turkey-market operations and cross-border services

    High
  • Weak custody, client asset or technology controls

    High
  • Incomplete AML, sanctions and transaction monitoring framework

    High
  • Banking or PSP plan prepared after the application strategy

    High

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Activity fit for this route

Review which crypto activities fit within the scope of this route.

Exchange
Conditional

Exchange activity may require additional scope or separate licensing.

Custody
Conditional

Custody may require separate review or additional controls.

Brokerage
Conditional

Brokerage or OTC activity typically fits within scope.

Wallet provider
Conditional

Exchange activity may require additional scope or separate licensing.

EU market
Not suitable

EU passporting not available from this route.

Startups
Not suitable

High setup complexity means significant budget is needed.

Not sure if your model fits? Request a licensing assessment

Is Turkey CASP authorisation right for your project?

Best for

  • Turkey market entry and local CASP operations

Not suitable for

  • Low-capital startups and EU passporting
  • Projects without a prepared banking strategy

Banking difficulty is high for this route. Prepare a banking strategy before committing to the Turkey route.

Core requirements

Use this section to check the main regulatory and operational requirements before committing to a jurisdiction.

Required share capitalFrom 1 300 000 EUR
Required
Local staffRequired
Required
Physical officeRequired
Required
AuditRequired
Required

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Local substance plan — Turkey

A credible local presence can be as important as the filing itself. Regulators, banks and payment providers may all review whether the company has real operating substance.

Local staff

Required

Required

At least one locally-accountable staff member or director is expected.

Physical office

Required

Required

A genuine office presence is expected, not a nominal registered address.

Audit

Required

Required

External audit is required for ongoing supervision compliance.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Service price (professional fees)Application preparation and professional services.
52 800 EUR EURFixed
State fee
On an individual basisFrom
Annual supervision feeRecurring annual cost after authorisation.
On an individual basisFrom
Required share capitalMust be held, not an expenditure.
From 1 300 000 EURFrom
High ongoing cost

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown — Turkey

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Cost itemAmount
Service priceApplication preparation and professional services.€52,800
Required share capitalMust be held, not an expenditure.€1,300,000

Summary

One-off costs
€1,352,800
Annual (year 1)
€0
Total year 1
€1,352,800

Adjust to convert to your base currency.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Application process

The sequence below shows the usual project flow. Exact steps depend on the regulator, business model and application scope. Turkey — From 3 months.

Total timelineFrom 3 months
  1. Pre-assessment and scope review

    1–3 weeks

    Define the activity scope, governance model and target markets before formal preparation.

  2. Company setup in Turkey

    2–6 weeks

    Establish legal entity, appoint local staff and set up local operating structure.

  3. Documentation and compliance packBottleneck risk

    3–8 weeks

    Prepare AML/CFT policies, governance documents, controls framework and application materials.

  4. Application submission to Sermaye Piyasası Kurulu

    1–2 weeks

    Submit complete application with all required documentation.

  5. Regulator reviewBottleneck risk

    From 3 months

    Regulator reviews the application. May request clarifications. Incomplete files extend this phase.

    Depends on: File quality and completeness

  6. Authorisation or registration confirmation

    1–4 weeks

    Regulator confirms authorisation or registration. Commence operations.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

What can delay or increase cost

These factors are most likely to affect timelines and budgets for this route.

High setup complexity
High

Setup complexity is rated high for Turkey. Company setup, governance and documentation take longer than average.

Likely impactAdd 4–8 weeks to the preparation phase.
MitigationStart company setup and governance planning immediately after scope confirmation.
Banking difficulty
High

Banking difficulty is rated high. Opening accounts for crypto businesses in Turkey requires extensive documentation.

Likely impactBanking can delay or block operations for 3–6 months after authorisation.
MitigationIdentify and pre-qualify banking partners before submitting the application.
Regulatory risk
High

Regulatory risk is rated high. Enforcement focus and compliance expectations are above average for Turkey.

Likely impactAdditional review rounds, requests for evidence, or timeline extension.
MitigationPrepare an evidence-based compliance file. Engage local counsel early.
High maintenance cost
Medium

Ongoing supervision, audit and compliance costs are above average. Budget for these separately from the application fee.

Likely impactRecurring annual cost significantly above the one-time service price.
MitigationModel annual compliance costs before committing to this route.
Application completeness
Medium

Incomplete files are the most common cause of delay. Regulator queries extend review by weeks or months.

Likely impactEach regulator query adds 2–6 weeks to the review phase.
MitigationUse a structured compliance pack. Review file completeness before submission.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Banking and PSP strategy in Turkey

Prepare a banking package before filing: ownership, source of funds, flow of funds, AML, custody and client geography.

Banking difficulty
High

Reflects how challenging it is to open and maintain business bank accounts in this jurisdiction.

Medium PSP availability
Medium

Reflects availability of payment service providers willing to onboard crypto-licensed entities.

A licence or registration does not guarantee bank account or payment provider approval. Banking feasibility should be reviewed before the application strategy is finalized.

Preparation checklist

  • Business model and transaction flow description
  • AML/KYC and sanctions controls
  • Expected fiat currencies and payment corridors
  • Source of funds and source of wealth documentation
  • Custody, token and counterparty policies where relevant

Business model fit — Turkey

Assess how well this route covers your planned activities.

Fit score

Good fit
0/6
Partial fit
5/6
Poor fit
1/6

Turkey may not cover your primary activities

Consider an alternative route that better matches your activity profile.

CMB/SPK application profile

Regulatory authority · Turkey

Sermaye Piyasası Kurulu

Turkey CASP is a serious local authorisation with meaningful setup complexity, regulatory risk and ongoing maintenance, not a fast registration.

Official regulator website
Regulatory reputation
Medium

Moderate reputation; assess banking and partner acceptance case by case.

Setup complexity
High

Reflects documentation depth, governance requirements and expected review friction.

Regulatory risk
High

Reflects likelihood of delays, additional information requests or policy uncertainty.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Compliance documentation

Most crypto licensing routes require a documented compliance framework before submission, not only after approval.

  • Required
    AML/CFT policy and risk assessmentDocument your customer risk model and control framework.
  • Required
    Customer due diligence (CDD) procedures
  • Required
    Enhanced due diligence (EDD) proceduresFor high-risk clients and jurisdictions.
  • Required
    Transaction monitoring system and rules
  • Required
    Sanctions screening procedures
  • Required
    Suspicious activity reporting (SAR) process
  • Required
    MLRO / Compliance officer appointmentLocal accountability may be required.
  • Recommended
    Board-approved governance charter
  • Conditional
    Outsourcing policy and monitoringRequired if functions are outsourced.
  • Recommended
    ICT / cybersecurity policy
  • Required
    Complaints handling procedure
  • Required
    Annual external audit engagementRequired for ongoing supervision compliance.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Documents to prepare

Preparing these materials before filing reduces regulator questions and helps with banking or payment provider onboarding.

0 / 12 required
Required
Recommended
Depends on scope

Corporate documents

AML and compliance

Operational

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Risk assessment

Main risk dimensions for the Turkey route.

Regulatory risk
High

Route risk rating — regulatory risk: High. Weak compliance, vague scope or insufficient controls increase review risk.

Mitigation: Prepare an evidence-based compliance file before submission.

Banking difficulty
High

Route risk rating — banking difficulty: High. Authorisation does not guarantee bank account opening.

Mitigation: Start banking outreach and compliance preparation before the application.

Setup complexity
High

Route risk rating — setup complexity: High.

Maintenance cost
High

Route risk rating — maintenance cost: Very high. Budget for ongoing compliance, fees and supervision separately.

Regulatory reputation
Medium

Route risk rating — regulatory reputation: Medium.

This content is for general orientation only. Crypto regulation changes quickly and the final scope should be confirmed through a jurisdiction-specific legal review before filing or incorporation.

Turkey CASP vs alternatives

Compare Turkey with EU MiCA/CASP for passporting, Dubai VASP for UAE positioning, and DAB/VASP routes if the project is not Turkey-market led.

Current

Turkey

CASP

Price
52 800 EUR
Timeline
From 3 months
Passporting
No passporting
Banking
High
Reputation
Medium

Malta (MiCA)

MICA

Price
20 700 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
Medium
Reputation
High

+ EU/EEA passporting and CASP framework

Requires EU nexus and MiCA-level file

View route

Dubai (VASP)

VASP

Price
22 300 EUR
Timeline
From 6 months
Passporting
No passporting
Banking
Medium
Reputation
High

+ Broader non-EU VASP route

Not a Turkey local-market authorisation

View route

Canada (MSB)

MSB

Price
20 600 EUR
Timeline
From 2 months
Passporting
No passporting
Banking
Medium
Reputation
High

+ Faster registration for MSB-style models

Not enough for full exchange/custody scope

View route

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Turkey vs other CASP routes

Compare key parameters across CASP authorisation routes.

Sort by:

Check your readiness for Turkey CASP authorisation

Documented AML/CFT policies, risk assessment, compliance officer.

Share capital

From 1 300 000 EUR minimum capital required.

AML/CFT framework

Documented AML/CFT policies, risk assessment, compliance officer.

Governance structure

Board, management, accountability chain defined.

Banking preparation

Banking strategy and identified partners.

Local substance plan

Local staff and office in Turkey.

Readiness status

Answer the criteria on the left to see your readiness status.

Frequently asked questions

No. Turkey CASP does not provide EU/EEA passporting. EU/EEA market access should be reviewed through MiCA/CASP.

Usually no. Turkey CASP involves high capital, high setup complexity and very high maintenance cost, so it is a demanding route.

Check service scope, required capital, local office, local staff, governance, audit, banking and whether the business truly needs Turkey market entry.

Compare MiCA/CASP for EU access, Dubai VASP for UAE positioning, and other VASP/DAB routes for non-EU operations.

The page is not legal advice and should not be relied on as a substitute for advice from qualified counsel in the relevant jurisdiction.

Your dedicated specialists

  • Enrico Kärvinen

    Enrico

  • Rein Tammik

    Rein

  • Jurata Žukaitė

    Jurata

  • Andrej Kazlauskas

    Andrej

  • Marta Värna

    Marta

  • Katrin Lepik

    Katrin

  • Inga Stankavičiūtė

    Inga

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