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By principle decision i-SPK.37.10 dated 26 October 2026, the Capital Markets Board of Türkiye (Sermaye Piyasası Kurulu) raised the financial thresholds for clients who request professional client treatment from investment firms. The decision also updates qualified investor conditions and removes the rules that preserved the status of existing clients. Clients who obtained either status under the former amounts must evidence that they meet the current conditions, or they may give only sell orders in instruments reserved for qualified investors.
What changed
The Board announced the decision in its Bulletin no. 2026/74, the official bulletin through which it publishes its decisions. A principle decision (ilke kararı) is a general decision by which the Board sets binding rules of application for market participants. The Board adopted this decision at meeting no. 75 as decision no. 1899 on 26 October 2026.
For clients seeking professional client status on request, the total financial assets threshold rises from TRY 10 million to TRY 50 million. The transaction volume threshold rises from TRY 5 million to TRY 25 million. The Board has also re-determined the amounts under which legal entities are treated as professional clients, although the bulletin does not state those figures.
Several Board communiqués (tebliğ, secondary legislation issued by the Board) define qualified investor conditions by reference to the professional investor rules. Those qualified investor conditions are updated as a result of the new thresholds.
The decision removes the exception that principle decision i-SPK.37.7 of 18 December 2025 had created for qualified investors buying participation units of real estate investment funds and venture capital investment funds. Those investors are subject to the amounts that apply to qualified investors generally.
The decision repeals the third paragraph of i-SPK.37.7, which preserved professional client and qualified investor status. It also repeals the first paragraph of principle decision i-SPK.37.8 of 10 March 2026, which contained a further preservation rule. The updated Guide on Investment Services and Activities and Investment Firms (Yatırım Hizmet ve Faaliyetleri ile Yatırım Kuruluşlarına İlişkin Rehber) is published on the Board's website.
Clients who acquired either status under the amounts in force before the decision date are required to evidence to their investment firm, in writing or electronically, that they meet the current conditions. This duty extends to investors in real estate and venture capital investment fund units. A client who does not provide that evidence may give only sell orders in the qualified-investor instruments it holds.
Who is affected
The most directly affected group consists of individual investors who hold professional client or qualified investor status with an investment firm in Türkiye on the basis of the former amounts. The bulletin draws no distinction by nationality or residence, so foreign individuals with accounts at Turkish investment firms fall within its scope.
Investors in real estate investment fund and venture capital investment fund units are directly affected as a distinct group. They lose the exception granted in December 2025 and are measured against the general qualified investor amounts.
Legal entities treated as professional clients, including foreign companies that hold investments through Turkish investment firms, are directly affected by the re-determined legal entity amounts.
Investment firms are directly affected because they receive the evidence from clients and must apply the sell-only restriction where it is missing. This places an internal obligation on their compliance and operations functions.
Funds whose units may be sold only to qualified investors are indirectly affected. The higher amounts and the removal of the exception reduce the number of investors eligible to buy their units.
What this means in practice
- An individual whose eligibility rested on financial assets of TRY 10 million no longer meets the threshold unless those assets reach TRY 50 million.
- A client classified on the basis of transaction volume between TRY 5 million and TRY 25 million falls below the revised threshold of TRY 25 million.
- The decision accepts evidence only in written or electronic form, and that evidence goes to the investment firm with which the client works.
- Units of real estate and venture capital investment funds held without fresh evidence become sell-only positions for the client concerned.
- Corporate clients cannot confirm their position from the bulletin alone, because the re-determined legal entity amounts appear only in the updated Guide.
- For investment firms, the order restriction attaches to specific instruments in a specific client's account, which ties order-handling controls to the evidence on file.
Frequently asked questions
Does the order restriction oblige a client to sell existing holdings?
The bulletin does not require any disposal of holdings. It limits a client who has not evidenced eligibility to sell orders in instruments that only qualified investors may trade. The bulletin also sets no deadline for providing the evidence.
What happens if a client's assets later fall below the thresholds?
This situation concerns clients who acquired status under the amounts in Articles 31 and 32 of Communiqué III-39.1 on the Principles of Establishment and Operation of Investment Firms. If such a client later falls below the required financial amounts, Article 30 of that Communiqué and Article 9 of Communiqué III-5.2 apply. The repealed paragraph of i-SPK.37.8 no longer preserves the status in that case.
What should existing professional clients and qualified investors do about this?
An individual client's first step is a comparison of current financial assets or transaction volume against the TRY 50 million and TRY 25 million thresholds. A corporate client makes the same comparison against the legal entity amounts in the updated Guide. A client who meets the conditions must deliver written or electronic evidence to its investment firm to keep buying qualified-investor instruments. A client who cannot meet them retains its existing positions but may place only sell orders in those instruments.
Source: Capital Markets Board of Türkiye Bulletin No. 2026/74 — https://spk.gov.tr/data/6adf00818f95db2330f22009/2026-74.pdf (26 October 2026)
This article is for general information purposes only and does not constitute legal advice.