1. Introduction
The issue of "interest accrual on protection accounts," which has long been on the agenda of the Turkish fintech ecosystem, reached its final legal standing in 2026. While this regulation aims to integrate funds held on behalf of users into the financial system to prevent them from remaining idle, it also enables payment institutions to establish a sustainable income model.
2. Legal Basis of the Regulation
This new era, for which the full compliance process began in April 2026, is based on updates to Article 36/A of Law No. 6493. Reinforced by the regulation change published in the Official Gazette on March 19, 2026, this legal framework gained technical detail through the 2026 Operational Guide issued by the CBRT. This body of regulation dictates, with mandatory provisions, which banks and which instruments can be used for interest accrual transactions.
3. The Interest Accrual Regime and the "16:30" Rule
The new legislation has introduced a critical change to the end-of-day calculation hours, which are the heart of operational processes. The calculation limit, previously 15:00 on full business days, has been shifted to 16:30, and to 12:00 on half business days. After this time slot, institutions may only utilize the remaining balances in protection accounts in low-risk, high-liquidity instruments such as Treasury Bills, Government Bonds, or Overnight Repo. The most critical point here is that the method of sharing the interest income between the institution and the user must be transparently defined in the framework agreements.
4. Risk Management and Legal Liability
The opportunity provided by the legislation brings with it heavy audit obligations. Institutions cannot subject the entirety of the funds to interest accrual; they must maintain a liquidity buffer at ratios determined by the CBRT to meet instantaneous payment requests. Furthermore, interest accrual activities must under no circumstances risk the principal integrity of user funds. Violations of the 16:30 rule or the selection of improper instruments are subject to heavy administrative fines under Law No. 6493, as well as sanctions ranging up to the suspension of operating licenses.
5. GRD Partners Perspective and Conclusion
For fintech institutions to transform this process from a risk factor into an efficient operation, it is essential to revise user framework agreements and banking protocols in accordance with the 2026 updated legislation. Implementing automation tools to prevent manual calculation errors will strengthen operational compliance.
As of April 2026, the interest accrual regime has become a new standard in the Turkish fintech market, offering a significant competitive advantage for institutions that achieve full regulatory compliance. At GRD Partners, we continue to provide comprehensive compliance consultancy to our clients in this delicate balance between technology and law.
For detailed analysis and legal support, you can contact our team at info@grd-partners.com.