LEGAL GLOSSARY
Payment service
A payment service is one of the services listed in Article 12 of Law No. 6493 that intermediate the depositing, transfer or withdrawal of funds. They include operating a payment account, money transfer, issuing or accepting payment instruments such as cards, money remittance, intermediating bill payments, initiating payment orders and account information services. As a rule, only banks, electronic money institutions, payment institutions and PTT may provide these services; the power to grant permits and to supervise lies with the Central Bank of the Republic of Türkiye (Türkiye Cumhuriyet Merkez Bankası).
Scope
Article 3/1-s of Law No. 6493 defines a payment service as the services listed in Article 12 of the Law: operating a payment account, money transfer, including payment by card and direct debit, issuing or accepting a payment instrument, money remittance, intermediating bill payments, initiating payment orders, consolidated presentation of account information, and other transactions to be determined by the Central Bank of the Republic of Türkiye (Türkiye Cumhuriyet Merkez Bankası, TCMB). Transactions such as direct cash payments, payments by negotiable instruments and instruments usable only within a limited network fall outside the scope under the conditions set out in the Law (Art. 12/2).
Payment service providers are banks, electronic money institutions, payment institutions and PTT; persons other than these and the Central Bank cannot provide payment services (Art. 13). In the Law, “Bank” refers to the Central Bank of the Republic of Türkiye; the permitting and supervision of payment institutions belong to it (Art. 14, 21).
Practical significance
Whether a business model that transfers money, receives payments or holds funds on behalf of users counts as a payment service determines whether a Central Bank permit is required; the assessment is made on the basis of the list and exceptions in Article 12. Operating without a permit as a payment institution or an electronic money institution is regulated as a criminal offense in Article 28. A framework contract with the user is concluded in writing or by remote methods accepted by the Central Bank; the Central Bank may impose limits on fees and commissions (Art. 12/3-4). Under a Central Bank regulation, crypto-assets cannot be used directly or indirectly in payment services.
Commonly confused concepts
A payment order under the payment services legislation is the instruction that a payment service user gives to the provider for a payment transaction to be carried out (Art. 3/1-p); this is entirely different from the payment order that an enforcement office sends to a debtor under the Enforcement and Bankruptcy Law (İcra ve İflas Kanunu). A payment service is also confused with the issuance of electronic money: issuing electronic money is a separate activity subject to a permit and may be carried out only by banks, PTT and electronic money institutions (Art. 18); a payment institution permit alone does not confer this authority.
Sources and scope
- 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-b, p, s; Art. 12, 13, 14, 18, 21, 28(accessed: September 24, 2026)
- Legislation Information System of the Presidency of the Republic of Türkiye (T.C. Cumhurbaşkanlığı Mevzuat Bilgi Sistemi) — Regulation on Not Using Crypto Assets in Payments · Art. 4(accessed: September 24, 2026)
The explanation is for general information; a specific case must be assessed separately.