Is there any rule on the minimum number of shareholders of payment and electronic money institutions? What is the minimum number of shareholders required to establish an institution?
Law No. 6493 contains no provision on the minimum number of shareholders of institutions. Accordingly, under the provisions of Turkish Commercial Code No. 6102, it is possible to establish a payment institution or an electronic money institution with a single shareholder.
What really matters in the ownership structure
Although no minimum number of shareholders is required, the suitability of shareholders is important. The financial strength and track record of people who will hold shares in the institution, and the lawfulness of their funds, are assessed in the licensing process.
Notification or approval may also be required for share transfers and the acquisition of qualifying holdings. Setting up a clean and traceable ownership structure from day one therefore also makes later capital increases easier.
Although a single-shareholder structure is possible, startups that will raise investment usually clarify their shareholder agreements from the start.
