LEGAL GLOSSARY
Digital wallet
A digital wallet is an electronic device, online service or application in which information on a payment account or a payment instrument such as a card is stored and which enables payments to be made with that information. The Central Bank’s payment services regulation defines it as a payment instrument and reserves this service for authorized payment service providers. A wallet used for crypto-assets, by contrast, is separately defined in the Capital Markets Law and is subject to different rules.
Scope
In everyday language, “digital wallet” is used as a common name for mobile payment applications that store card details, electronic money accounts and crypto-asset wallets. In legislation, however, there are two separate definitions:
- Payment services: Article 3/1-zz of the Regulation on Payment Services, Issuance of Electronic Money and Payment Service Providers defines a digital wallet as a payment instrument in which the payment account or payment instrument information defined by the customer is stored and with which payment transactions can be made. Under Article 4/A of the Regulation, payment service providers may offer this service; applications in which only the same institution’s own payment account and its own issued payment instrument can be defined are not considered a digital wallet service.
- Crypto-assets: Article 3/1-aa of Capital Markets Law No. 6362 (SPKn) defines a wallet as software, hardware, a system or an application that enables the transfer of crypto-assets and the online or offline storage of those assets or of the private and public keys relating to them.
Practical significance
An institution that will offer a digital wallet service must at least be authorized to issue payment instruments; if the wallet is used as a payment instrument at merchants and funds are transferred through this institution, then, except for the exceptions in the Regulation, authority to issue electronic money is also required (Regulation Art. 4/A). On crypto-asset platforms, the principle is that customer assets are held in the customer’s own wallet; if the alternative is preferred, custody may be provided only by authorized banks or institutions (SPKn Art. 35/C). For the user, it matters which regime the wallet is subject to and who controls the private keys.
Commonly confused concepts
A digital wallet is different from electronic money: electronic money is a monetary value, whereas a digital wallet is an instrument that enables payment account or payment instrument information to be stored and used, and it may store card information alone. A digital wallet under the payment services legislation is assessed under Law No. 6493 and the Central Bank regulation, whereas a crypto-asset wallet is assessed under the SPKn. A digital wallet is also distinct from a payment account opened in the customer’s name (Law No. 6493, Art. 3/1-r).
Sources and scope
- Legislation Information System of the Presidency of the Republic of Türkiye (T.C. Cumhurbaşkanlığı Mevzuat Bilgi Sistemi) — Regulation on Payment Services, Issuance of Electronic Money and Payment Service Providers · Art. 3/1-zz, Art. 4/A(accessed: September 24, 2026)
- Legislation Information System of the Presidency of the Republic of Türkiye (T.C. Cumhurbaşkanlığı Mevzuat Bilgi Sistemi) — Capital Markets Law No. 6362 · Art. 3/1-aa; Art. 35/C(accessed: September 24, 2026)
- Legislation Information System of the Presidency of the Republic of Türkiye (T.C. Cumhurbaşkanlığı Mevzuat Bilgi Sistemi) — Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions · Art. 3/1-ö, r; Art. 18(accessed: September 24, 2026)
The explanation is for general information; a specific case must be assessed separately.