- The financial asset threshold for professional client status on request rises from TRY 10 million to TRY 50 million; the transaction volume threshold from TRY 5 million to TRY 25 million.
- The exception introduced in December 2025 for real estate investment funds (GYF) and venture capital investment funds (GSYF) has been removed. Qualified investors in these funds are now subject to the general thresholds.
- Investors who obtained professional or qualified investor status under the previous amounts must document to their investment institution that they meet the current requirements. Otherwise they may only place sell orders in these instruments.
- Sections 4.3 and 12.5 of the Guide on Investment Funds were also amended.
When and where was the decision published?
In its Bulletin 2026/74 dated 26 October 2026, the Capital Markets Board of Türkiye published two principle decisions: i-SPK.52.4.ao (decision 75/1897), amending the Guide on Investment Funds, and i-SPK.37.10 (decision 75/1899), updating the professional client and qualified investor amounts. The updated guides are published on the CMB website.
Professional client thresholds: TRY 50 million and TRY 25 million
Under the rules for investment institutions, the total financial assets required to be treated as a professional client on request rise from TRY 10 million to TRY 50 million, and the transaction volume requirement from TRY 5 million to TRY 25 million. The amounts for legal entities to qualify as professional clients were also revised.
Because the qualified investor conditions in several CMB communiqués refer to the professional investor rules, the qualified investor conditions have been updated as well.
Exception for real estate and venture capital funds removed
The exception granted by principle decision i-SPK.37.7 (18 December 2025, decision 65/2354) for qualified investors buying units of real estate investment funds and venture capital investment funds has been removed. Investors in these funds are now subject to the amounts that apply to qualified investors in general.
The third paragraph of the same decision, which protected existing professional client or qualified investor status, has also been repealed, as has the first paragraph of decision i-SPK.37.8 (10 March 2026, decision 14/492) on the same subject.
What should existing investors do?
Investors who became professional clients or qualified investors under the previous amounts before the decision date, including investors in real estate and venture capital funds, must document in writing or electronically to the investment institution they work with that they meet the current requirements. Investors who do not do so may only place sell orders in instruments reserved for qualified investors; they cannot buy more.
For clients whose financial amounts fall below the required level after obtaining the status, the procedure in Article 30 of the Communiqué on Investment Institutions (III-39.1) and Article 9 of Communiqué III-5.2 will apply.
Our view
The decision moves the qualified investor definition to a higher asset level and steers the investor base of real estate and venture capital funds towards a more institutional profile. For investors, the most urgent issue is documentation: anyone holding units in a Turkish real estate or venture capital fund should confirm their status with their broker or portfolio management company.
At FT Portföy we are working through this process together with the investors in the funds we manage. Our team is available for any questions.
Frequently asked questions
What is the new qualified investor threshold in Türkiye?
For professional client status on request, the financial asset threshold is now TRY 50 million and the transaction volume threshold TRY 25 million. The qualified investor conditions, which refer to these rules, have been updated accordingly.
Is there still a separate threshold for real estate and venture capital fund investors?
No. The exception introduced in December 2025 has been removed; investors in these funds are subject to the general qualified investor amounts.
Will I lose my fund units if I do not provide documents?
No, your units remain yours. Until you document that you meet the new requirements, you may only place sell orders in these instruments.
When did the decision take effect?
With the CMB decision dated 26 October 2026; details are in CMB Bulletin 2026/74.
Source: CMB (SPK) Bulletin 2026/74 (26 October 2026) · CMB Guide on Investment Services and Institutions (i-SPK.37.10, in Turkish).
This is not investment advice. The information, comments and opinions in this article do not constitute investment advice. Investment advisory services are provided only under an investment advisory agreement between the client and an authorised institution. The views expressed are the author's personal opinions and may not suit your financial situation or your risk and return preferences. Investment decisions should not be based solely on this information. Past performance is not an indicator of future results.
Serkan Topaktaş
Chairman of FT Portföy, a portfolio management company licensed by the Capital Markets Board of Türkiye (CMB/SPK), managing real estate and venture capital funds in Istanbul.