TCMB Regulation Amendment: Interest-Bearing E-Money Protection Accounts
The Central Bank of the Republic of Türkiye (TCMB) has enacted an important regulation in the payments and electronic money sector through an amendment published in the Official Gazette No. 33201 on March 19, 2026.
Through this amendment ("Amendment") to the Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers ("Regulation"), the framework for interest accrual on funds held in electronic money ("e-money") protection accounts on an overnight basis has been clearly established.
Current Status: What Was Previously Regulated?
Under the existing Regulation, payment institutions were permitted to earn interest on payment funds. However, no such explicit provision existed for e-money institutions.
This situation has been a significant point of debate in the sector since the regulation was first published; it remained unclear whether this distinction was an intentional choice or an inadvertent gap.
The Amendment has resolved this debate, and it is now explicitly provided that e-money protection accounts may earn interest.
What Does the Amendment Cover?
The Amendment can be evaluated under three main headings:
Interest-Bearing E-Money Protection Accounts
1. Interest-Bearing E-Money Protection Accounts
Through a provision added to Article 35 of the Regulation, it is now explicitly stated that interest accrual on an e-money protection account held at a bank on an overnight basis does not constitute a violation of the second and fourth paragraphs of that article.
With this regulation, e-money institutions now have a clear legal basis for evaluating funds held in protection accounts on an overnight basis.
New Provision: Article 36/A
The Amendment adds Article 36/A to the Regulation, titled "Interest Accrual on Payment Funds and Funds Collected as Electronic Money Backing."
This article provides a comprehensive framework for the interest accrual process. The principal provisions are as follows:
Balances in payment and e-money protection accounts may be invested in a separate interest-bearing account to be opened at the bank where the protection account is held.
Payment funds in foreign currency and amounts held in e-money protection accounts are excluded from the scope of interest accrual.
The principal and net interest amount, after deduction of the bank's commission and other statutory deductions, are transferred to the protection accounts on the next business day.
The commission rate and calculation method for the interest accrual service must be clearly specified in the contract with the bank.
The principal and net interest amounts of accrued funds are tracked separately; the account containing interest amounts may be freely used by the institution.
Institutions whose operating license has been temporarily suspended are prohibited from earning interest during that period.
In overnight interest accrual transactions, only low-risk and highly liquid assets may be used; preservation of principal is essential.
Update to End-of-Day Balance Calculation Times
The Amendment also includes a technical provision.
The times at which end-of-day balances of payment funds to be deposited in protection accounts are calculated have been updated:
For full business days: 15.00 → 16.30
For half business days: 11.00 → 12.00
This change aims to align operational processes with more realistic time windows in practice.
Legal and Sectoral Assessment
This Amendment should be regarded as an extremely positive development, as it addresses a regulation the sector has long awaited.
For e-money institutions, the ability to earn interest on funds held in protection accounts on an overnight basis creates a significant financial opportunity. This will particularly enable the generation of additional resources for:
customer acquisition and loyalty programs,
promotional and incentive mechanisms,
financing of operational expenses
At the same time, this development will also enhance the competitive position of e-money institutions relative to banks to a certain extent.
Operational and Compliance Obligations
Nevertheless, this regulation also creates important responsibilities for institutions.
In particular:
effective management of interest-bearing accounts,
proper separation of principal and interest,
careful structuring of contracts with banks,
maintenance of sufficient liquidity for instant payment obligations
have now become more critical.
This may require institutions to undergo a significant compliance process in terms of technical infrastructure, accounting systems, and human resources.
Comparative Law Perspective
The inclusion of this long-existing capability in the European Union into Turkish legislation reflects an important aspect of harmonization efforts in the payments services sector.
However, EU regulations also provide for alternative mechanisms such as insurance for the protection of funds. Turkish legislation does not yet appear to include such alternatives.
On the other hand, PSD3 draft regulations discuss the use of settlement accounts with payment systems as a protection mechanism. It is possible that this approach may be addressed in Türkiye in the future.
Conclusion
This regulation by the TCMB is an important step supporting the development of the e-money sector.
However, Article 36/A merely establishes the general framework; the importance of secondary regulatory guidance remains significant for details that may arise in practice.
For this reason, it is crucial for sector participants to closely monitor any clarifications and guidance that may be issued by the TCMB.
The regulation entered into force as of its publication date.
Av. Umut Balcı