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The Communiqué Amending the Communiqué on Information Systems of Payment and Electronic Money Institutions and Data Sharing Services of Payment Service Providers in the Field of Payment Services (the “Amending Communiqué”), published in the Official Gazette dated 04.09.2026 and numbered 33360, introduced significant amendments to remote identification processes.
The Communiqué on Information Systems of Payment and Electronic Money Institutions and Data Sharing Services of Payment Service Providers in the Field of Payment Services (the “Communiqué”), which is subject to the amendment, sets out the procedures and principles governing the management of information systems used by payment and electronic money institutions in conducting their activities and the audit of such systems by authorised independent audit firms, as well as the data sharing services of payment service providers in the field of payment services.
The Amending Communiqué revised the methods for verifying identity documents used in remote identification, permitted the remote identification of non-Turkish nationals using passports subject to certain conditions, and exempted certain transactions from the mandatory application of remote identification requirements.
The principal amendments introduced by the Amending Communiqué and their potential implications in practice are summarised below.
Definition of “Identity Document” Introduced
The Amending Communiqué introduced a definition of “identity document” into the Communiqué. Accordingly, an identity document means an identity card as defined under the Regulation on the Identity Card of the Republic of Türkiye.
In parallel with this amendment, references to the “T.R. Identity Card” and certain references to “documents” in the Communiqué have been replaced with “identity document”, thereby aligning the terminology with the newly introduced definition.
Principles for Verification of Identity Documents in Remote Identification Have Been Revised
For remote identification, the information required from the person whose identity is to be verified and the relevant identity document must first be obtained.
As a primary method, the authenticity of the identity document and the accuracy of the data and information contained therein will be verified using near-field communication (NFC). In addition, the authenticity, integrity and condition of the identity document, including whether it has been damaged or tampered with, will be checked, with particular regard to its security features that are visually distinguishable under white light, photograph and signature. The process of visually checking the front and back of the identity document will be recorded without interruption.
Alternative Methods May Be Used Where NFC Verification Cannot Be Performed
Where verification using NFC cannot be performed for any reason, the authenticity of the identity document and the accuracy of the data and information contained therein will be verified using at least 1 of the following methods: optical character recognition, a card reader, or another method determined by the Central Bank of the Republic of Türkiye after obtaining the opinion of the Financial Crimes Investigation Board.
In such cases, the security features of the identity document, in the types and numbers specified in the General Communiqué of the Financial Crimes Investigation Board (Serial No. 19), will also be checked, and the document will be examined for authenticity, integrity, damage and tampering. The process of visually checking the front and back of the identity document will also be recorded without interruption.
Application of Remote Identification Provisions Will Not Be Mandatory for Certain Transactions
The Amending Communiqué provides that the application of remote identification provisions will not be mandatory for certain transactions and products where remote communication tools are used.
Accordingly, where remote communication tools are used in processes relating to information, agreements, receipts and similar documents required for anonymous prepaid instruments; one-off payment transactions for which identification is not mandatory under Law No. 5549 and the relevant legislation and which do not constitute an ongoing business relationship; and electronic money issuance and payment transactions specified in paragraph 1 of Article 2.2.11 of the General Communiqué of the Financial Crimes Investigation Board (Serial No. 5), the application of remote identification provisions will not be mandatory.
Remote Identification of Non-Turkish Nationals Using Passports Has Been Permitted
The Amending Communiqué permits non-Turkish nationals to undergo remote identification using passports, subject to certain conditions.
Remote identification of such persons will be carried out in accordance with the principles set out in Article 4/C of the General Communiqué of the Financial Crimes Investigation Board (Serial No. 19). A passport compliant with International Civil Aviation Organization (ICAO) 9303 standards and equipped with NFC functionality must be used for remote identification.
Accordingly, for the remote identification of non-Turkish nationals using passports, the passport must satisfy the prescribed technical requirements and the remote identification requirements determined by the Financial Crimes Investigation Board must also be complied with.
Entry into Force
The Amending Communiqué, which is to be implemented by the Governor of the Central Bank of the Republic of Türkiye, entered into force on 04.09.2026.
Assessment and Conclusion
The Amending Communiqué provides further detail on the methods for verifying identity documents in the remote identification processes of payment and electronic money institutions and specifies the alternative methods that may be used where NFC verification cannot be performed. It also permits the remote identification of non-Turkish nationals using passports that comply with ICAO 9303 standards and are equipped with NFC functionality.
While the amendment directly affects the technical controls applicable to identity document verification in remote customer onboarding, it also removes the mandatory application of remote identification provisions for certain transactions and products.
In this respect, payment and electronic money institutions should review their remote identification processes and technical infrastructure for compliance with the new requirements and should also take into account the relevant Financial Crimes Investigation Board regulations when conducting the remote identification of foreign customers.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.