Our company provides an online payment infrastructure to legal entities that sell over the internet. The amount being paid first passes through our company's virtual POS into our company's bank accounts, and our company then pays it into the merchants' accounts on the agreed settlement dates. Is the service we offer a payment service? Is a license required to carry out this service?
Yes. Unless the service falls within the exceptions listed in the second paragraph of Article 12 of the Law, it is a payment service under the Law, and a license must be obtained from the Board in order to offer a payment service under this business model.
Why is it considered a payment service?
Here, the company holds the money in its own account on behalf of the merchant and forwards it on a specific date. This structure means that funds are held under the control of a third party, so it is natural for it to be considered a payment service.
Banks also run similar models under merchant agreements, but banks are already authorized institutions. Companies other than banks can offer this model only by obtaining a license.
Before starting such a business model, companies should clarify whether the service falls under the exceptions in the law and, if there is any uncertainty, consult the competent authority.
