2026 Investment Ecosystem: A Strategic Beginning
The first quarter of 2026 has been the year of transition from “quantity to quality” for
the startup world. We are observing a significant momentum in capital flows,
particularly towards ventures focused on Artificial Intelligence (AI), Green Energy, and
Data Infrastructure. Türkiye continues to remain on the radar of global investors with
both its vision of becoming a regional technology hub and its updated regulations.
| Artificial Intelligence Leading capital flows as the dominant investment theme of Q1 2026. | Green Energy Sustainability-focused ventures attracting major institutional interest. | Data Infrastructure Strategic backbone investments rising sharply across the region. |
Information from the Regulator Side
While a busy quarter in the regulatory fields is left behind, authority decisions are determining the
direction of the sector. Both the Central Bank of the Republic of Türkiye (CBRT) and the Capital
Markets Board (CMB) have been active in shaping compliance expectations for payment
institutions, electronic money firms, and crypto asset service providers alike.
| New Licences from the CBRT | Crypto Sector Approvals in Progress |
| The Central Bank of the Republic of Türkiye has continued to support competition in the market by granting new electronic money (e-money) licences during the January3March 2026 period. These licences signal a continued commitment to fostering a competitive, innovation-friendly payment landscape. | Licence applications and approval processes submitted to the Capital Markets Board (CMB) for Crypto Asset Service Providers (CASPs) are meticulously ongoing. Eforts to grant full approvals in the sector are progressing carefully, with the CMB prioritising systemic soundness and investor protection throughout the review process |
| Sector Expectation: Full compliance with eIDAS (Electronic Identification, Authentication and Trust Services) and mutual recognition processes to facilitate cross-border digital trade remains a top priority. Clarification of crypto taxation processes is equally anticipated by market participants. |
Fintech: Crypto Asset Service Providers
The regulatory environment surrounding Crypto Asset Service Providers (CASPs) has seen subs-tantial activity in Q1 2026, with both MASAK and CMB introducing measures that raise the bar for compliance, identity verification, and interinstitutional cooperation.
| Change of Thresholds and Identity Verification | Custody Agreements and Authorisation Certificates |
| With MASAK and CMB regulations, the thresholds forapplying simplified measures have been updated, and additional audits have been introduced for foreign politically exposed persons. As of 28 February 2026, the way has been paved for AI-based remote identification methods 4 a transformative step for digital onboarding. Furthermore, with the regulation dated 12 March 2026, the working procedures of the Financial Crimes Coordination Board have been modernised to strengthen interinstitutional cooperation for the prevention of money laundering. | In the processes of CASPs signing agreements with custody institutions and obtaining authorisation certificates from the CMB, “conditional time extensions” have been granted depending on the expansion of custody infrastructures. This approach acknowledges the operational realities of a growing sector while maintaining regulatory integrity and supporting the compliance capacity of market participants. |
Payment and E-Money Sector
The payment and e-money sector has entered a new compliance paradigm in Q1 2026. Two pivotal developments have reshaped the risk landscape for institutions operating in this space, requiring immediate attention from legal and compliance teams.
Interest Yield Practices
Operational clarifications regarding the processes of institutions yielding interest on user funds have been provided, highlighting liquidity management in the sector. These clarifications are expected to reduce ambiguity and support more consistent practice across institutions of varying sizes.
CBRT Administrative Monetary Fine Guideline
With the guideline published in February 2026, the fines to be imposed on payment and e-money institutions have been structured on a “revenue-ba-sed” model. Especially for institutions with an annual revenue exceeding 500 million TRY, the fact that the fine amount can double due to the multiplier effect has raised compliance risk to the highest level. Robust compliance programmes are no longer optional 4 they are existential imperatives.
Data Centre Investments: Strategic Opportunity Window
As of 2026, global data centre investments are expected to exceed 270 billion dollars, and Türkiye is in the position of a rising star in the region. Its geographical advantages, combined with data localisation regulations and newly introduced investment incentives, create a compelling proposition for both domestic and international investors seeking strategic footholds in the region.
$270B
Global Investment
Expected global data centre investment volume in 2026.
$1.5B
HIT-30 Budget
Budget allocated under the HIT-30 Programme for data centre development. volume in 2026.
2026
Pivotal Year
Türkiye’s window of strategic opportunity as a regional data hub.
Investment Incentives & Guarantees
The 1.5 billion dollar budget within the HIT-30 Programme and the legal guarantees introduced by the Cybersecurity Law offer tangible opportunities for data centre investors seeking long-term certainty.
Cybersecurity & Energy Standards
The new guideline 4 extending from energy infrastructure to cybersecurity standards 4 has clarified the legal infrastructure suppor-ting Türkiye’s vision of becoming a leading regional data hub.
Gaming, Cybersecurity & Digital Copyright
One of the most critical developments for investors in the startup and gaming world is the new obligations introduced to the gaming sector in Q1 2026. These changes carry significant implications not only for domestic developers but also for foreign game distributors with substantial Turkish user bases. Compliance timelines are tight, and the financial exposure for noncompliance is considerable.
Foreign Game Distributors
Foreign-sourced game distributors with a daily access of more than 100,000 users from Türkiye are now required to appoint a natural or legal person representative in Türkiye. This requirement mirrors broader platform accountability trends seen across other digital sectors.
Parental Control Obligations
An obligation to provide parental control tools has been imposed on game providers. In case of violation, bandwidth throttling up to 90% and administrative monetary fines up to 30 million TRY are envisaged 4 making swift compliance a commercial as well as legal necessity
Digital Copyright regulations closely concerning startups producing digital content have begun to clarify in Q1 2026, introducing obligations around data transparency and financial accountability.
Data Sharing Obligation
Digital platforms must submit copyright calculation data to ICTA (BTK) for transparent remuneration.
Revenue-Based Fines
Up to 5% of annual digital service revenue in Türkiye; up to 10% for systematic violations.
Legal Note: Platforms should audit copyright calculation methodologies and ensure data submission pipelines to ICTA are operational. The revenue-based fine model means larger platforms face proportionally higher exposure.
Regulatory Outlook: What to Watch in Q2 2026
The pace of regulatory change in Q1 has set the tone for the remainder of 2026. Several key themes are expected to continue developing through Q2, with implications that will affect strategic planning for startups, fintech companies, and their investors. Legal teams and boards alike should be monitoring the following developments closely.
Each of these themes carries distinct legal and operational implications. Pekin Bayar Mizrahi’s Fintech & IT Department is actively monitoring developments across all four areas and will provide timely guidance as the regulatory picture evolves through the second quarter.
Contacts
For detailed legal analysis on any of the developments outlined in this bulletin, or for bespoke advice tailored to your business, our Fintech & IT Department is available to assist.
You can also visit our website to access detailed articles prepared on all these topics and more.
Selin Bayar
SeniorPartner
+90 212 359 57 00
s.bayar@pekin.com.tr
Dr.CeylanNecipoğluLL.M.,CIPP/E
Junior Partner
+90 212 359 57 00
c.necipoglu@pekin.com.tr
This bulletin is for informational purposes only and does not constitute a legal opinion.
Pekin Bayar Mizrahi | Fintech & IT Department 4 Q1 2026