CASP(CRYPTO) License in Turkiye
Obtaining a CASP License in Turkiye
The regulatory framework governing crypto-asset service providers in Turkiye (“KVHS” – internationally referred to as CASPs) was brought directly within the scope of capital markets legislation through statutory amendments enacted in 2024, two years prior to MiCA. Turkiye entered the licensing phase earlier than Europe.
Through Law No. 7518, which amended Capital Markets Law No. 6362, crypto-asset service providers were explicitly defined, and their activities were made subject to authorization and supervision by the Capital Markets Board of Turkiye (“CMB”).
Accordingly, in Turkiye, companies wishing to:
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Operate a crypto-asset trading platform
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Provide order transmission and execution services
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Provide crypto-asset custody services
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Offer transfer or intermediary services
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are required to obtain an operating license from the CMB.
As GlobalB Law, closely involved in the development of crypto regulation in Turkiye and recognized as a leading legal team in the sector, we manage the CASP licensing process not merely as a technical filing, but as a strategic institutional structuring project.
1.Structure of the CASP Regulatory Framework in Turkiye
In Turkiye, crypto-asset service providers are subject to the following regulatory framework:
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Capital Markets Law
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CMB regulations regarding Crypto-Asset Service Providers
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Relevant secondary legislation and board resolutions
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MASAK (AML/CFT) legislation
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KVKK (Personal Data Protection Law)
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Turkish Commercial Code and Code of Obligations
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Competition Law
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The new system mirrors a MiCA-like structure, imposing high standards in capital adequacy, governance, operational risk, information systems, and investor protection.
2.Scope of License
The principal activities requiring a CMB license include:
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Operation of crypto-asset trading platforms
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Provision of crypto-asset custody services
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Transfer and intermediary services
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Other crypto services defined by the CMB
The scope of activities directly impacts capital requirements and organizational structure.
3.Core Requirements for a CASP License in Turkiye
1. Minimum Paid-In Capital
The minimum capital requirement determined by the CMB must be satisfied.
Capital levels vary depending on the type of services provided.
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2. Corporate Governance and Organization
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Qualified board structure
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Internal control system
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Risk management unit
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Compliance department
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Segregation of duties principle
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3. AML / CFT Compliance System
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Risk-based customer acceptance policy
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Transaction monitoring and suspicious transaction reporting
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Appointment of a compliance officer
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Training and internal audit mechanisms
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4. Information Systems and Cybersecurity
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CMB-compliant IT infrastructure
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Data hosting obligations in Turkiye
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Business continuity and disaster recovery plans
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Independent IT audit
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5. Protection of Investor Assets
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Segregation of client assets
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Custody mechanism
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Transparent fee structure
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Clear and unambiguous user agreements
4.Types of Licenses
1. Platform License
For crypto-asset trading platforms.
2. Custody Institution License
For activities involving the custody of client crypto assets.
5.CMB Application Process
Grandfathering Regime and Two-Stage Licensing System for New Applicants
The regulatory regime for crypto-asset service providers in Turkiye was fundamentally restructured following amendments to the Capital Markets Law No. 6362 introduced by Law No. 7518.
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Two separate categories emerged in this transformation process:
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Companies operating prior to the regulation (Grandfathering Regime)
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New companies to be established and applying after the CMB secondary regulations dated March 13, 2025
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The legal framework for both processes is explained below.
Two-Stage Licensing System for Newly Established Companies
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Following the secondary regulations published by the CMB on March 13, 2025, a two-stage authorization system was introduced for newly established and newly applying companies.
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1. Establishment Authorization (Pre-Authorization Phase):
​New crypto-asset service providers cannot obtain a direct license. The first phase is the Establishment Authorization.
​Key Elements of the Establishment Authorization Application
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At the application stage:
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The company may not yet have fully paid its capital.
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A draft Articles of Association may be submitted.
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A board structure consisting of at least three members must be envisaged.
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The scope of planned activities must be described in detail.
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An organizational chart and business model must be presented.
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Shareholding structure and ultimate beneficial ownership information must be disclosed.
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Board members’ resumes (criminal records, diploma copies, CVs) and fit-and-proper declarations must be submitted.
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At this stage, the CMB evaluates:
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The financial strength of the founding shareholders
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The competence of the management team
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The legal compliance of the planned business model
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The potential for integration into the capital markets system
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Granting establishment authorization does not confer the right to commence operations.
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2. Operational Authorization (Operating License):
After obtaining establishment authorization, the second stage begins: Operational Authorization.
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Timeline
From the date of establishment, authorization is granted:
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An operational license application must be submitted within 6 months.
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This period may be extended for an additional 6 months upon request
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Failure to apply within the prescribed period may render the establishment authorization void.
Main Requirements for Operational Authorization
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Pursuant to the secondary regulations, the operational authorization application must include:
1. Fulfillment of Capital Requirement
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The minimum paid-in capital requirement must be satisfied.
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Capital must be paid in cash and in full.
2. Organizational Structure Fully Established
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Internal control system
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Risk management unit
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Compliance unit
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Information systems officer
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General management structure
3. Information Systems and IT Infrastructure
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Technical infrastructure compliant with CMB regulations
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Business continuity plan
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Backup systems
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Independent IT audit report
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MKK (Central Securities Depository) integration
4. AML / CFT Compliance Mechanism
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MASAK-compliant system
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Transaction monitoring software
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Appointment of compliance officer
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Suspicious transaction reporting infrastructure
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Travel Rule integration
5. Protection of Client Assets
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Segregation mechanism
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Custody model
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Operational control procedures
6. Independent Audit and Financial Infrastructure
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Independent auditor agreement
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Financial adequacy documentation
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At the operational authorization stage, the CMB conducts a detailed legal, technical, and financial review.
Upon approval, the company acquires licensed status as a crypto-asset service provider.
Accordingly, for companies entering Turkiye, the process is structured similarly to European regulatory systems; however, the CMB has broad discretionary authority and conducts a file-based assessment.
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Under the New Regime, the Licensing Process:
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Is not merely company formation,
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Requires structuring equivalent to a capital markets institution,
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Necessitates integrated technical, financial, and legal compliance.
In particular:
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Proper structuring of the establishment authorization file,
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Designing a regulation-compliant business model,
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Effective management of the 6-month operational authorization period
are of critical importance.
The legal positions of companies under the grandfathering regime and newly applying companies differ, and strategy must be determined accordingly.
Advantages of a CASP License in Turkiye
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Credibility under CMB supervision
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Long-term regulatory certainty
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Institutional investor attractiveness
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Sustainable banking relationships
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Transparent and strong operational structure
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Future-ready regulatory framework
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Turkiye’s leading crypto market
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Direct access to the financial system
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Competitive advantage through licensed status
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Institutional investor-ready structure
Taxation Framework
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Corporate income tax
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VAT applications
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Withholding tax obligations
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Transfer pricing
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Independent audit
Structuring depends on the business model.
Frequently Asked Questions
Can a foreign-owned company obtain a license?
Yes. A joint-stock company with foreign shareholders may be incorporated in Turkiye.
Is the license indefinite?
The operating license is indefinite; however, it is subject to ongoing supervision.
Must IT infrastructure be located in Turkiye?
Certain data hosting obligations apply under CMB regulations.
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​GlobalB Law is one of the most well-known and active legal teams in crypto regulation in Turkiye.
We:
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Represent major platforms operating in the crypto sector
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Analyze CMB and MASAK regulations at the implementation level
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Integrate IT and compliance projects with technical teams
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Structure the licensing process from an investor's perspective
We approach the CASP license application as the creation of an investment-ready, institutional, and sustainable structure.
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Premium CASP License Package
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Company incorporation and Articles of Association structuring
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Capital planning
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AML / Compliance system establishment
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Internal control and risk management documentation
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Legal compliance analysis of information systems
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User agreements and platform legal infrastructure
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Preparation of the CMB application file
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Management of correspondence with the CMB
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Strategic representation during the review process​
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KVKK compliance project
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IT audit preparation
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MASAK process design
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Tax structuring consultancy
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Banking and custody institution relations
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HR-Payroll Consultancy ​
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A CASP license is not merely a permit. This process requires holistic structuring of capital, technology, compliance, and corporate governance. As GlobalB Law, we are ready to be your legal partner in building the strongest and most sustainable crypto structures in Turkiye.
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globalblaw.com
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