Introduction

From November 1, 2025, a new regulation (Communiqué No. 2025/24) amends the rules under Communiqué No. 2020/4 concerning the fees that banks can charge their corporate clients. This change, issued in the Official Gazette (number 33021) on September 18, introduces standardized fee caps, timing requirements, and new obligations that could affect how corporate entities negotiate with banks.  In this post, we unpack what the regulation means in practice, its implications, and how companies can prepare to stay compliant and protect their interests.

Key Changes Under Communiqué No. 2025/24

1. Standardization of Commitment Fees
One of the most significant changes is regarding commitment fees. Under the new regulation, the commitment fee (charged by banks for the unused portion of a loan commitment) must not exceed 0.20% of the committed credit. Importantly, banks are not allowed to charge a separate fee for renewals of the commitment.

2. Increased Disbursement Fee on Revolving Loans
The new rules also adjust the disbursement fee (charged when funds are actually drawn down). For revolving loans (loans that allow repeated drawdowns up to a limit), the disbursement fee is now capped at 1.10%, up from the previous 1.00% cap for such loans.

3. Caps and Timing for Merchant Fees in Card Transactions

• Debit card merchant fees (for purchases of goods/services) and transactions where funds are made available the next day are capped at 1.04%. This aligns the treatment of debit payments more closely with credit card standards. 

• For non-installment credit card purchases, banks must make funds available to merchants no later than 40 days after the next day of transaction. 

• For debit cards, the maximum period is 15 days. urkishlawblog.com+1

4. Equal Treatment for Prepaid and Account-to-Account Payments
Fees and timing limitations that apply to debit card transactions will now also apply to prepaid card transactions and account-to-account merchant payments. This is designed to remove arbitrage or unfair discrepancies between different payment types. 

Why These Changes Matter

These regulatory changes hold multiple consequences for businesses in Turkey:

• Fee predictability & budgeting: By standardizing fee caps (e.g. commitment and disbursement fees) and limiting merchant fees, companies can better forecast their financial costs in borrowing and card payment settlements.

• Improved cash flow for merchants: Shorter time frames for receiving funds (especially with debit and prepaid payments) can help merchants with liquidity. Waiting 15 days instead of an open-ended period can make a difference, particularly for smaller businesses.

• Reduced cost uncertainty in bank transactions: Prior to the amendment, banks could charge higher or variable fees, or charge for renewals separately. These adjustments lessen the risk of surprise costs.

• Leveling the playing field across payment instruments: Previously, prepaid cards or less common payment methods could have worse terms. Extending the same timing and caps to them ensures fairer financial terms for businesses using different payment methods.

Transition, Compliance & Adaptation Strategies

If you are a corporation or merchant doing business in Turkey, here are key steps to adapt to the new regulation:

• Review existing contracts and banking agreements: Check the terms of your loan agreements, merchant fee arrangements, and credit/debit card processing contracts to see if they exceed new caps. Where they do, prepare to renegotiate or contest overcharges.

• Audit merchant payment flows and financial reporting: Verify when merchants are being paid and ensure that banks or payment processors are meeting the new timing requirements. Delays beyond what is allowed may entitle you to claim non-compliance.

• Update financial models: Incorporate new fee caps into your projections and budgets. This helps in both cost planning and in negotiating with banks, knowing what is legally enforceable.

• Ensure payment processing systems align: If you offer multiple payment methods (credit, debit, prepaid, account-to-account), ensure your systems and contracts are set to benefit from the updated regulations.

• Seek legal advice if needed: The application of some provisions may vary depending on contract details or bank practices. An attorney familiar with Turkish banking regulations can help interpret clauses, prepare negotiation positions, or handle disputes.

Potential Challenges and Areas to Watch

While the changes bring more certainty, some practical challenges may arise:

• Legacy agreements: Banks may try to rely on pre-existing contracts that don’t conform to new caps. Determining whether contracts can be amended or are grandfathered can require legal review.

• Enforcement & compliance monitoring: Regulations are only as good as their enforcement. Businesses will need to monitor whether their banking partners are complying, which may require legal or auditing efforts.

• Contractual ambiguity: Some contracts may have vague language around when fees are “renewed” or how “commitment” is defined. Disagreement with banks may arise.

• Cost of renegotiation: Banks may resist lowering fees or adjust other terms (interest rates, collateral requirement) in response. Negotiation may imply trade-offs.

What This Means for Foreign Entities & Investors

If you’re a foreign business operating or investing in Turkey, these regulatory changes are particularly important:

• Transparency for cross-border financing: Clarity around fees and payment timing makes Turkey a more predictable environment for financing operations or sales.

• Better terms for local partnerships: Local businesses can now negotiate from stronger footing when dealing with Turkish banks and payment providers, knowing what the law allows.

• Risk mitigation: Reduced uncertainty in transactional fees helps mitigate financial risk associated with cash flow delays or unexpected banking charges.

• Regulatory awareness as a competitive advantage: Companies that align early with the regulation benefit in credibility and reduced costs — potentially giving them a market advantage over those that lag.

Conclusion

The Amendment Communiqué (2025/24) represents a meaningful change in the relationship between banks and their corporate clients in Turkey. With new caps on fees, stricter timing for transfers, and more equal treatment across payment instruments, the regulation aims to increase fairness, transparency, and predictability.

For businesses — especially those relying heavily on borrowing or dealing with card transaction merchant fees — it’s essential to review existing contracts, update financial forecasts, and ensure banking partners adhere to the new norms by November 1, 2025.

At Ecrin Nezir Solicitors, we are closely monitoring both the implementation and compliance phases of this regulation. Our experts are ready to assist corporate clients in reviewing agreements, negotiating with banks, and addressing disputes related to overcharges. Feel free to reach out for tailored advice so your business both meets its legal obligations and secures the best possible terms.