On 26 October 2026 Turkiye’s Capital Markets Board (CMB, in Turkish SPK) raised the professional-client amounts: financial assets from TL 10 million to TL 50 million, trading volume from TL 5 million to TL 25 million. Clients who qualified on the old amounts must now certify, or can only sell the qualified-investor instruments they hold.
Two private clients of a Turkish brokerage house were treated as professional clients before 26 October 2026. Each holds the Advanced Level Capital Market Activities Licence. What happens to them now?
| Client | Position | Result |
|---|---|---|
| Tolga: deposits TL 28.0m, listed shares TL 22.0m, fund units TL 10.5m | Financial assets total TL 60.5m, above TL 50m. With the licence, he meets two of the three criteria. | He can certify to the firm, in writing or electronically, that he meets the conditions, and keeps his status. |
| Selin: deposits TL 4.0m, securities TL 8.0m | Financial assets total TL 12.0m: above the old TL 10m, below the new TL 50m. Her trading volume is below TL 25m, so only the licence is met. | She cannot certify. On the qualified-investor instruments she holds, she can only place sell orders. |
Who is a professional client, and why does it matter?
An investment firm, such as a brokerage house, must sort every client into one of two classes: professional or general (retail). The Communique on the Principles of Establishment and Operation of Investment Firms (III-39.1) sets the rules in Articles 30 to 32. A professional client is one with the experience, knowledge and expertise to take its own investment decisions and assess the risks it takes (Art. 31).
The class decides the protection. A firm must warn professional clients in writing about the rules they do not benefit from (Art. 31(2)). For brokerage and public-offer services, the suitability test, which checks whether a product matches the client’s knowledge, is mandatory only for general clients (Art. 33).
There are two routes. Banks, brokers, funds, insurers and public bodies are professional by type. Companies meeting two of three size tests are professional too. Other clients may ask in writing to be treated as professional if they prove two of three conditions: trading volume, financial assets, or professional experience (2 years in a senior finance role, 5 years as a capital market specialist, or an Advanced Level or Derivatives licence). Under Art. 32(2) the Board may change the amounts. Under Art. 32(3), a client meeting only the financial-assets condition counts as a qualified investor.
What are the old and new amounts?
| Test (Communique III-39.1) | Communique text | From 19 Dec 2025 (i-SPK.37.7) | From 26 Oct 2026 (i-SPK.37.10) |
|---|---|---|---|
| On request, Art. 32(1)(a): volume in each 3-month period of the last year (and at least 10 transactions) | TL 500,000 | TL 5 million | TL 25 million |
| On request, Art. 32(1)(b): financial assets (cash deposits and capital market instruments) | over TL 1 million | TL 10 million | TL 50 million |
| Company, Art. 31(1)(d): total assets | TL 50 million | TL 500 million | TL 2.5 billion |
| Company: annual net revenue | TL 90 million | TL 1 billion | TL 4.5 billion |
| Company: equity | TL 5 million | TL 50 million | TL 250 million |
A company needs two of the three company tests. Experience (Art. 32(1)(c)) is unchanged. The decision calls this an update of the amounts. Other Board communiques that refer to these rules are updated with it.
What else does the decision change?
- Real estate and venture capital funds. The exception from i-SPK.37.7 is removed. Buyers of real estate and venture capital investment fund units, who had kept the old amounts, now face the general amounts.
- Existing clients. Paragraph 3 of i-SPK.37.7 is repealed. Clients who became professional or qualified under the old amounts must first prove, in writing or electronically, that they meet the conditions now in force. Otherwise those holding instruments that qualified investors may trade can only place sell orders in them.
- Falling below the amounts later. Paragraph 1 of i-SPK.37.8 is repealed. A client who gained status and later drops below the amounts is handled under Art. 30 of III-39.1 and Art. 9 of the Communique on Sale of Capital Market Instruments (II-5.2). Read those articles for the steps.
Firms must also announce the higher amounts to clients (Guide).
What happens to a company client?
Anadolu Gida A.S. has total assets of TL 1.8 billion, net revenue of TL 3.0 billion and equity of TL 300 million. Before the decision it passed all three tests (above TL 500m, TL 1bn and TL 50m). Now the limits are TL 2.5bn, TL 4.5bn and TL 250m. Only equity (TL 300m against TL 250m) passes: one test of three. By this route it no longer qualifies.
What should investment firms do now?
- List every client classified as professional or qualified by the old amounts.
- Write to them: announce the new amounts and ask for supporting documents.
- Re-test each reply against the table and keep the documents (Art. 30(4)).
- For clients who do not certify, apply sell-only handling on qualified-investor instruments they hold.
From when does it apply?
The bulletin text of the decision (26 October 2026, Board Decision 75/1899, CMB Bulletin 2026/74) does not state a separate effective date. The Board’s updated Guide says the new amounts apply from the publication of the decision, 26 October 2026. No deadline for existing clients to certify appears in either text; confirm the timing with the Board or your firm’s compliance contact.
Legal basis
- Decision
- Principle Decision i-SPK.37.10, Board Decision Body decision of 26 October 2026, no. 75/1899, published in CMB Weekly Bulletin 2026/74 (item A.2)
- Parent communique
- Communique on the Principles of Establishment and Operation of Investment Firms (III-39.1), Articles 30 to 33; Art. 32(2) lets the Board change the amounts
- Earlier decisions
- i-SPK.37.7 (18 December 2025, 65/2354); i-SPK.37.8 (10 March 2026, 14/492)
Key facts
| Authority | Capital Markets Board of Turkiye (SPK) |
|---|---|
| Instrument | Principle Decision i-SPK.37.10, Board Decision Body decision no. 75/1899 |
| Applies from | 26 October 2026, per the Board’s updated Guide; the bulletin text states no separate date |
| Amounts | On-request clients: assets TL 50m, volume TL 25m. Legal entities: assets TL 2.5bn, revenue TL 4.5bn, equity TL 250m |
| Existing clients | Certify to the firm or place sell orders only on qualified-investor instruments |
| Repeals | i-SPK.37.7 paragraph 3; i-SPK.37.8 paragraph 1 |
| Last verified | 6 November 2026, against the CMB bulletin PDF, the CMB Guide PDF and the mevzuat.gov.tr text of III-39.1 |
Frequently asked questions
Do existing professional clients keep their status?
Only if they prove it. Clients who gained status under the old amounts must first certify to their firm, in writing or electronically, that they meet the conditions now in force. If they do not, those holding qualified-investor instruments can only place sell orders in them.
Is there a deadline for certifying?
Neither the decision text nor the Guide states one. Confirm with the Board.
What happens to investors in real estate and venture capital funds?
The exception from i-SPK.37.7, which kept the old amounts for buyers of those funds’ units, is removed. They face the general qualified-investor amounts.
What if a client later falls below the amounts?
Paragraph 1 of i-SPK.37.8 is repealed. The firm follows the procedure in Art. 30 of III-39.1 and Art. 9 of Communique II-5.2.
Sources (official)
- Capital Markets Board Weekly Bulletin 2026/74, 26 October 2026, item A.2: Principle Decision i-SPK.37.10 (75/1899) https://spk.gov.tr/data/6adf00818f95db2330f22009/2026-74.pdf
- Capital Markets Board, Guide on Investment Services and Activities and Investment Firms, updated by i-SPK.37.10 (Part BB) https://spk.gov.tr/data/61e496a11b41c60d1404d6b2/9%20Yat%C4%B1r%C4%B1m%20Hizmetleri%20ve%20Kurulu%C5%9Flar%C4%B1%20Rehberi%20(i-SPK.37.10)%20v3.pdf
- Communique on the Principles of Establishment and Operation of Investment Firms (III-39.1), Official Legislation Information System https://www.mevzuat.gov.tr/mevzuat?MevzuatNo=19131&MevzuatTur=9&MevzuatTertip=5
- CMB (SPK)
- Capital Market Regulations
- Professional clients
- Qualified investors
- Investment firms
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