Fintech
Payment-Institution Accounting in Türkiye: Safeguarding and Reconciliation
A 6493-focused guide to customer funds, safeguarding accounts, daily reconciliation, revenue and 2026 CBRT reporting.
Key takeaways
- Customer principal is a liability, not free cash or revenue.
- Unpaid payment funds at day-end must be placed in the safeguarding account by 16:30 the next business day, or 12:00 on a half business day.
- Safeguarded cash and customer liabilities require daily reconciliation.
- Service fees must be separated from protected principal at transaction level.
- CBRT reports need one controlled data dictionary across operations and accounting.
Important information
This article provides general information and is not legal, tax or investment advice. The outcome depends on the facts, the parties and current legislation.
Scope
This guide concerns payment institutions authorised by the CBRT under Law 6493. A technology-only fintech may not be subject to the same framework. For an authorised institution, every operational status from receipt of the payment order to settlement should have a defined accounting state.
Principal is not revenue
| Flow | Accounting nature | Control |
|---|---|---|
| Customer transfer principal | Customer/beneficiary liability | Safeguarding and settlement status |
| Service fee | Institution revenue | Contract and earning event |
| Bank/scheme/partner share | Cost or payable | Gross-net assessment |
| Refund/chargeback | Reversal or liability | Original transaction and ageing |
2026 safeguarding timing
Under the current Regulation, all payment funds unpaid at the end of the day are transferred to the safeguarding account by 16:30 on the next business day, or 12:00 on a half business day. The same timing applies to the end-of-day electronic-money balance. Service fees are excluded from safeguarded payment funds.
Daily three-way reconciliation
- Transaction platform by status
- Bank and safeguarding account by value date
- General ledger customer liability, protected cash, revenue and costs
- Exception ID, reason, age and owner
- Immediate escalation of any customer-fund shortfall
CBRT reporting control
- Load the 2026 ODEPA calendar into the close schedule
- Map every field to a system source and ledger account
- Version submitted and corrected files
- Approve capital, safeguarding and material-exception metrics before submission
Exception ageing and escalation
| Age/risk | Action | Escalation |
|---|---|---|
| Same day | Identify timing, bank, system or posting cause | Operations/finance owner |
| Next business day | Resolve or document expected settlement | Finance manager |
| Customer-fund shortfall | Immediate investigation and restoration action | Senior management/compliance |
| Recurring exception | Root-cause change and control test | Product/technology governance |
| Long outstanding | Accounting, customer and regulatory impact review | Management and advisers |
Revenue close
Define the event at which each fee is earned: authorisation, execution, settlement, subscription service or another contractual milestone. Separate refunds, waivers, scheme charges and partner shares. Where the institution acts as agent, the reported revenue may be the net fee rather than the underlying payment amount.
Month-end management pack
- Payment volume to net-revenue bridge
- Customer liability to safeguarded-cash reconciliation
- Highest intraday or end-of-day shortfall
- Refund, failure and chargeback rates
- Partner and bank margin
- Capital and regulatory limits
- Open exceptions and CBRT submission status
Frequently asked questions
Can safeguarded funds be shown as free cash?
No. They are subject to customer-fund protection and corresponding liabilities and should be distinguished from operating liquidity.
What is three-way reconciliation?
It compares operational transaction records, bank movements and accounting balances for the same population and cut-off.
When is a merchant commission recognised as revenue?
Review the contract, service completion, refund or chargeback terms and reporting framework. The deduction or payout date alone does not always determine recognition.
Is safeguarding reconciliation the same as bank reconciliation?
No. Required safeguarded funds, operational liabilities, safeguarded bank balances and accounting records are connected but need separate calculations and reconciliation.
Official sources
Legislation last reviewed: 1 August 2026
Mikail Ege
Certified Public Accountant · SMMM
Mikail Ege works across accounting, tax, financial reporting, financial advisory, fintech and payment institutions.
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