
No, it cannot.
Under the Communiqué, the service bank will not be able to provide services to interface developers resident abroad.
An interface developer is defined as a fintech company or other business that enables its customers to carry out their banking transactions by accessing the banking services offered by the service bank through the bank's APIs and open banking services, via a mobile app or web browser-based interface it has developed.
Under the Communiqué, service banks offering service model banking will be able to provide service model banking only to interface developers resident in Türkiye.
The details of the communiqué can be accessed from the link below:
https://www.bddk.org.tr/Mevzuat/DokumanGetir/1050
The reason for the residency requirement
This restriction was introduced so that data security and supervision can be carried out in Türkiye. It is more difficult to supervise an interface developer abroad and to impose sanctions in the event of a dispute.
Foreign fintechs can join this model by setting up a company in Türkiye or by working with a local business partner. This keeps the chain of responsibility clear.
Service banks also carry out security and compliance checks when choosing interface developers.


