If your company provides crypto-asset services and you are looking at both sides of this map, the first thing to understand is that Turkey and Montenegro are not running the same regime at different speeds. They are running different regimes.
Turkey put crypto inside its capital markets law: an authorisation, a capital floor measured in hundreds of millions of lira, a specific corporate form, a levy on your revenue, and a prison sentence for operating without permission.
Montenegro put crypto inside its anti-money-laundering law: an entry in a register, a documentary file, a reputation test on your directors and beneficial owner — and no capital requirement at all.
Neither is "the easier country". They impose different obligations at different moments, and the question that decides which applies to you is the same in both: not where your servers are, but who your marketing is pointed at. That test is written into both statutes.
Everything below is cited to statute, article and date, checked on 23 August 2026.
The structural difference in one table
| Türkiye | Crna Gora (Montenegro) | |
|---|---|---|
| Legal home of the regime | Capital Markets Law No. 6362, as amended by Law No. 7518 (Resmî Gazete 2 July 2024, no. 32590) | Zakon o sprječavanju pranja novca i finansiranja terorizma, Sl. list CG 110/23, 065/24, 024/25 |
| Instrument you obtain | Faaliyet izni + yetki belgesi (authorisation) — Art. 35/B(1) | Upis u registar (register entry) — Art. 40a |
| Supervisor | Sermaye Piyasası Kurulu (Capital Markets Board) | Komisija za tržište kapitala — Art. 131(1)(3) |
| Corporate form required | Anonim şirket, all shares registered, issued for cash — Communiqué III-35/B.1 Art. 5(1)(a)-(c) | No prescribed form; legal person, company, entrepreneur or natural person carrying on a business — Art. 40a(1) |
| Minimum capital (2026) | Platform TRY 250,000,000; custody institution TRY 630,000,000 | None prescribed |
| Ongoing state levy on revenue | 1% to the Board + 1% to TÜBİTAK, annually — Law 6362 Art. 130(5) | None in the AML law |
| Criminal exposure for operating without it | 3 to 5 years' imprisonment + judicial fine — Art. 109/A | No dedicated offence in the AML law's penalty chapter |
| How many hold it today | Provisional list of 55 entities, none of which the Board describes as authorised | One company in the register |
Türkiye: a capital markets licence, and a clock that has stopped
Law No. 7518 rewrote the position on 2 July 2024. Article 35/B(1) of Law 6362 now provides that crypto-asset service providers may not be established or begin operating without permission from the Board, and may carry on only the activities the Board determines. Article 35/B(2) adds a technical gate: permission may be granted only if the applicant's information systems and technological infrastructure meet criteria set by TÜBİTAK, the national research council.
The money numbers come from Communiqué III-35/B.2 (Resmî Gazete 13 March 2025, no. 32840). Article 34(1) sets the platform founding capital floor and Article 34(2) the custody institution floor. Article 53 then allows the Board to re-determine every figure in the Communiqué each year using the revaluation rate announced by the Ministry of Treasury and Finance — so the number in the Communiqué is not the number you must fund.
For 2026 the Board did exactly that. In Bulletin 2025/68 of 31 December 2025, implementing Board decision 30/12/2025 no. 68/2461 at a revaluation rate of 25.49%, the figures became:
| Threshold (Communiqué III-35/B.2) | In the Communiqué (13.3.2025) | Applicable for 2026 |
|---|---|---|
| Platform founding capital — Art. 34(1) | TRY 150,000,000 | TRY 250,000,000 |
| Custody institution founding capital — Art. 34(2) | TRY 500,000,000 | TRY 630,000,000 |
| Client assets threshold triggering +1.5% additional equity — Art. 35(4) | TRY 1,000,000,000 | TRY 1,250,000,000 |
| Equity level at which no additional equity is required — Art. 35(4) | TRY 1,500,000,000 | TRY 1,900,000,000 |
| Maximum client transfer approved by fully automated process — Art. 30(3) | TRY 1,000,000 | TRY 1,250,000 |
Article 35(1) then provides that equity may never fall below the founding capital figure, and Article 35(2) that at least 25% of equity must be paid-in or issued capital as at the sixth month of each year — a live balance-sheet obligation, not a one-off deposit.
On top of it, Article 130(5) of Law 6362 — inserted by Law 7518 — takes 1% of a platform's total annual revenue excluding interest income for the Board's budget and a further 1% for TÜBİTAK's budget, payable by the end of May each year. Very few jurisdictions charge a percentage of turnover for the privilege of being supervised. Model it before you model anything else.
Where the transition actually stands
This is the part most published summaries get wrong, because the dates in the Communiqué have been overtaken.
The transition ran through provisional Article 11 of Law 6362 (existing operators had one month from 2 July 2024 to declare that they would either apply for authorisation or wind down within three months) and then through provisional Article 1 of Communiqué III-35/B.1: an authorisation application by 30 June 2025 (paragraph 2), a custody contract and technical integration by 31 December 2025 (paragraph 5), and possession of the yetki belgesi — the authorisation certificate itself — by 30 June 2026 (paragraph 3), failing which the liquidation provisions in paragraph 6 apply.
That deadline did not bite. By decision 26/03/2026 no. 18/617, published in SPK Bulletin 2026/18, the Board resolved that both the custody-contract deadline in paragraph 5 and the authorisation deadline in paragraph 3 will be set after authorised custody institutions have begun providing crypto custody services to platforms on a widespread basis. No replacement date was given. The licensing clock in Turkey is now conditional on infrastructure that does not yet exist at scale, and the Board's power to extend is express in provisional Article 11(3) of the Law itself.
Meanwhile the Board's public list — 55 entities when we checked it on 23 August 2026 — carries a blunt caveat: "Faaliyette Bulunanlar Listesi'nin varlığı, bu listede yer alan kuruluşların ilgili mevzuat uyarınca yetkilendirildiği anlamına gelmemektedir" — the existence of the list does not mean the entities on it are authorised under the relevant legislation. Read that before you treat a counterparty's presence on the list as a licence.
Crna Gora: a register entry, and a register of one
Article 40a(1) requires any legal person, company, entrepreneur or natural person carrying on a business with a seat, residence or approved permanent residence in Montenegro that intends to provide crypto-asset services in Montenegro to be entered in the register before starting. Article 40a(2) catches the case people miss: a provider from an EU member state — not on the high-risk third-country list, authorised or registered at home — that wishes to provide those services in Montenegro must also be entered before starting. There is no passport into Montenegro. It is not in the EU.
Article 40b lists what goes in the file: identification data; proof of appointment of the AML compliance officer under Article 69; a criminal-record certificate evidencing good repute under Article 40r for each director, member, management body member and beneficial owner; a declaration that the responsible person knows the obligations under the Law; director data under Article 117(1)(3); and a business plan setting out the crypto services you intend to provide and how you will market them. Where those individuals are Montenegrin citizens, the supervisor obtains the criminal record itself.
The detail sits in the Commission's Pravilnik on keeping the register and assessing reputation, adopted at its 159th session on 10 December 2025 (ref. 01/9-1358/2-25). It requires the Annex I application form, a notarised declaration, an extract from the beneficial owners register, a notarised questionnaire no older than one month, criminal and misdemeanour record extracts no older than three months — and, in Article 8, that the application and its supporting documents be submitted physically. Article 9 provides that it enters into force on the eighth day after publication in Sl. list CG; we were not able to independently confirm the gazette number, so confirm that layer before you date-stamp anything in a filing.
What the file does not contain is a capital number, a technical audit, or an operating-conditions test. Article 40r is a fitness-and-propriety filter, not a solvency one.
The register itself is public. Checked on 23 August 2026, it contains a single entry: Artenx d.o.o. Podgorica, entered at the Commission's 195th session on 31 July 2026 — the entire regulated population, and the subject of our note on Montenegro's crypto register.
The trap both regimes share: your marketing decides your jurisdiction
Both countries answered the cross-border question recently, and both answered it the same way — by looking at who you are advertising to.
| Trigger that puts you in scope | Türkiye — Law 6362 Art. 99/A(1) | Crna Gora — AML Law Art. 40e |
|---|---|---|
| Physical presence | Opening a workplace in Turkey | Seat, residence, or place of business in Montenegro from which services are provided |
| Website / language | Creating a Turkish-language website | Having a ".me" domain extension on your website |
| Marketing | Promotion or marketing directly, or through persons or institutions resident in Turkey | Directing services, advertising or a marketing campaign, by any means, at persons seated or resident in Montenegro |
| Automated channels | — | Offering crypto-assets in Montenegro through one or more automated systems |
| Distribution | — | Distributing services through channels intended for persons seated or resident in Montenegro |
| Local contact point | — | A postal address or telephone number in Montenegro |
Turkey's provision goes further than a scope rule: Article 99/A(1) states that activity by platforms established abroad directed at persons resident in Turkey is unauthorised crypto-asset service provision. Combine that with Article 109/A and the exposure is criminal: an offshore platform with a Turkish-language site and Turkish-language marketing falls within the statutory description of unauthorised provision, for which Article 109/A prescribes three to five years' imprisonment and a judicial fine of 5,000 to 10,000 days on the officers of the legal person. Provisional Article 11(4) required foreign providers to end such activity within three months of 2 July 2024, and Article 99/A(3)(c) lets the Board order content removal and access blocking through the Access Providers Association.
Montenegro has no equivalent criminal provision. Articles 40a to 40r contain no dedicated fine for providing services without registration; the penalty chapter that begins at Article 137 attaches to obliged-entity duties, and imposes EUR 5,000 to EUR 20,000 on a legal person for the listed breaches — which do include the Article 40f transfer-information (travel rule) duties. Enforcement of the register itself runs administratively: refusal under Article 40b(8), deletion under Article 40d(1), and, in between, pasivizacija — suspension of your status under Article 40d(2), during which you may not provide services at all while the supervisor decides.
That asymmetry is the most decision-relevant difference between the two countries. In Turkey the downside of getting scope wrong is criminal; in Montenegro it is administrative, and the practical risk is a suspended status that stops your business.
Three things this comparison does not settle
Payments. Turkey answered separately and in the negative: the Central Bank's Ödemelerde Kripto Varlıkların Kullanılmamasına Dair Yönetmelik (Resmî Gazete 16 April 2021, no. 31456), in force from 30 April 2021, provides in Article 3(2) and (3) that crypto-assets may not be used, directly or indirectly, in payments and that no service may be provided towards such use. Montenegro's crypto rules live entirely inside the AML law and Articles 40a to 40r say nothing either way about crypto as a means of payment — which is not the same as saying it is money there. If your model settles obligations in tokens, that gap is where to start, and our note on buying real estate with crypto in Montenegro covers the property-side version of the same question.
Tax. Neither regime's licensing text tells you what you will pay. Montenegro's corporate treatment — and the genuinely open question of whether a token disposal is a capital gain there — is set out in our piece on the tax treatment of crypto for Montenegrin companies. On the Turkish side, the comprehensive crypto tax bill introduced in March 2026 was removed from the General Assembly text on 27 March 2026 and did not become law; we could not verify that position against a primary parliamentary record, so treat it as a matter to confirm rather than a settled premise.
MiCA. Neither country is in the EU, so neither is inside the MiCA passport, and an authorisation in one does nothing for you in the other. What MiCA does and does not change for Montenegro is set out in Montenegro's crypto rules versus MiCA.
Before you choose a jurisdiction, price the obligation you will actually carry
The comparison that matters is not which registration is faster, but which set of continuing obligations your business can carry for five years.
In Turkey that means a funded balance sheet at the 2026 figures, a TÜBİTAK-benchmarked technology stack, a custody relationship you do not control the timing of, and 2% of gross revenue leaving the business every May. In Montenegro it means a short file, a reputation test that reaches your beneficial owner, physical filing — and then the AML compliance load that begins the moment you are registered, which we set out in what registration actually starts in Montenegro and in the banking problem that follows it.
If your company is weighing the two, or already has a footprint in one and is being advised it has none in the other, send us the marketing and distribution picture — the domains, the languages, the channels, the local numbers — before the structure is fixed. Under both Article 99/A(1) and Article 40e that picture, not the incorporation certificate, determines what you need. Our Turkish fintech and crypto work is described on the Türkiye fintech and crypto page, the Montenegrin side on the fintech and crypto page, and you can reach us through the contact page.
