Türkiye's SPK raises the professional client asset test to TL 50 million

Türkiye's Capital Markets Board raised the financial assets criterion for clients seeking professional status to TL 50 million from TL 10 million on 26 October, and the trading volume criterion to TL 25 million from TL 5 million, its bulletin 2026/74 said.

The change is principle decision i-SPK.37.10, taken by the board's decision-making body under decision 75/1899. The board's press release of the same day said the amounts for legal persons to count as professional clients were reset in line with it, and that the qualified investor conditions in several communiqués, which refer back to the professional investor rules, have been updated too. This explainer sets out what changed, from those documents and the board's updated guide.

The amounts are two of three criteria. Under Article 32 of the Investment Firms Communiqué, III-39.1, a client asking for professional status must meet at least two of them: the trading volume test, the financial assets test, and at least two years in a senior finance role, five years as capital markets staff, or an advanced capital markets or derivatives licence, the updated guide says. A client who meets the financial assets test alone counts as a qualified investor.

The amounts that applied until now

A client notice from the broker İş Yatırım listed the amounts for new applications under articles 31 and 32 of the communiqué after the threshold updates published on 19 December 2025: total assets of TL 500 million, annual net revenue of TL 1 billion, equity of TL 50 million, trading volume of TL 5 million and financial assets of TL 10 million. The new decision multiplies the last two by five. The updated guide sets the new amounts for legal persons at total assets of TL 2.5 billion, annual net revenue of TL 4.5 billion and equity of TL 250 million.

The notice said the amounts in force before 19 December 2025 continued to apply to qualified investors buying units of real estate investment funds and venture capital investment funds. That exception came from principle decision i-SPK.37.7 of 18 December 2025, and the board has now removed it, so those investors face the same amounts as other qualified investors, the bulletin said.

What happens to clients who already qualify

Decision i-SPK.37.7 also had a paragraph protecting clients who had become professional clients or qualified investors under the earlier amounts, and the İş Yatırım notice told clients their status would continue even if their assets later fell below the new amounts. The board has repealed that paragraph.

Clients who gained the status before the board's decision under the amounts then in force must now first show their investment firm, in writing or electronically, that they meet the conditions in the rules, the bulletin said. If they do not, a client holding instruments that only qualified investors may trade can give only sell orders in those instruments. That applies to holders of real estate and venture capital fund units as well.

The board also repealed the first paragraph of principle decision i-SPK.37.8 of 10 March 2026, which dealt with keeping the status. A client who gained the status through the amounts in articles 31 and 32 of the Investment Firms Communiqué, III-39.1, and later falls below them is now handled under the procedure in Article 30 of that communiqué and Article 9 of Communiqué III-5.2, the bulletin said.

What brokers and fund managers have to change

The board amended articles 4.3 and 12.5 of its Guide on Investment Funds at the same meeting, under decision 75/1897. The bulletin sets no transition period for existing clients to document their position.

The obligation to document falls on the client, and the bulletin refers to the conditions in the rules rather than to a list of amounts. Until a client does so, the sell-only limit applies to the instruments that only qualified investors may trade, not to the rest of the account.

Other recent fund rules in Türkiye are set out in the legal powers behind the fund investigation and in a parliamentary bill on interim payments to investors in 131 liquidated funds.