I. INTRODUCTION
The Decision has been prepared for the purpose of fulfilling the duties assigned to BRSA within the framework of the Action Plan for Combating Illegal Betting, Games of Chance and Gambling in Virtual Environment, which entered into force with Presidential Circular No. 2025/18 dated October 31, 2025. Additionally, it is part of the coordinated macro-prudential decisions taken to strengthen financial stability in coordination with the Ministry of Treasury and Finance and the Central Bank of the Republic of Türkiye, within the scope of evaluations made at the Financial Stability Committee meeting dated January 21, 2026.
The legal basis of the Decision is Article 93 and Additional Article 1 of the Banking Law, Articles 9 and 14 of the Credit Cards Law, and Article 22 of the Regulation. The Decision targets multifaceted objectives such as efficient use of financial resources to support lower income groups, strengthening financial stability, protecting financial consumers, preventing fraud, effective combating of illegal gambling, and compliance with international regulations.
II. CREDIT CARD USAGE IN TÜRKİYE AND CURRENT SITUATION
According to December 2025 data shared in BRSA’s explanatory press release dated January 31, 2026, there are striking statistics regarding credit card usage in Türkiye.
As of December 2025, there are approximately 40.7 million unique credit card users in Türkiye. Of these users, 30.6 million, or approximately 75 percent, have credit card limits below 400 thousand TL. The ratio of users with credit card limits below 750 thousand TL within total credit card ownership is approximately 90 percent.
The total individual credit card limit in the sector is approximately 13.3 trillion TL. However, a striking feature of this figure is that only 21 percent of the total limit is being used, while 79 percent remains unused.
The share of users with limits exceeding 750 thousand TL in the total credit card limit is 48 percent. The credit card utilization rates of these users remain at approximately 20 percent.
III. CONTENT OF BRSA DECISION
1. Regulations Regarding Issuance of New Credit Cards and Limit Increases
Sub-paragraph 1 of Section A of the Decision regulates the principles to be applied in the issuance of new credit cards or the increase of the card limits of existing credit cards.
According to the Decision, in determining the maximum total credit card limit to be granted for all credit cards provided to a natural person by all card-issuing institutions, monthly or annual average income must be taken into account, and the verification of such income must be carried out only through documents deemed suitable for proving income.
The Decision allows criteria such as prohibition or impediment status, economic and social status, model or scoring system results of persons to be evaluated in limit determination pursuant to legislation to be taken into consideration in the evaluation to be made in credit card applications or transactions for determining the final limit, provided that the maximum credit card limit to be determined by the method specified above is not exceeded.
2. B. Regulations Regarding Reduction of Existing Credit Card Limits
BRSA has envisaged a gradual reduction in the limits of cardholders with limits above certain threshold values.
Pursuant to sub-paragraph (a) of sub-paragraph 2 of Section A of the Decision, card-issuing institutions will carry out limit reductions by taking into account the period from January 2025 to the last account cut-off date before the Decision date for cardholders.
The first category covers cardholders whose total credit card limit obtained from card-issuing institutions as of the Decision date exceeds 400 thousand TL but does not exceed 750 thousand TL. The limits of the credit cards of cardholders in this category will be reduced by an amount corresponding to 50 percent of the amount in the period when the available limit was at its lowest, as of the account cut-off dates.
The second category covers cardholders whose total credit card limit obtained from card-issuing institutions as of the Decision date exceeds 750 thousand TL. The limits of the credit cards of cardholders in this category will be reduced by an amount corresponding to 80 percent of the amount in the period when the available limit was at its lowest, as of the account cut-off dates.
The Decision stipulates that in case the available card limit existing as of the limit reduction transaction date is less than the available card limit to be taken into account for limit reduction, the limit amount to be reduced shall be calculated by taking into account the available card limit existing as of the limit reduction transaction date.
Card-issuing institutions are required to complete the limit reduction transactions of cardholders by February 15, 2026.
The Decision introduces a special regulation in the evaluation of limit increase requests to be made after February 15, 2026 by cardholders whose total credit card limit falls to 400 thousand TL and below after limit reduction. It is envisaged that for limit increases up to 400 thousand TL by such cardholders, the provisions of sub-paragraph 1 of Section A of the Decision regarding income to be taken into account in the issuance of new credit cards or the increase of card limits of existing credit cards and the proof of such income shall not be applied, and all other limit increase requests shall be evaluated within the scope of the said provisions.
3. Transition Process and Final Compliance Obligation
Sub-paragraph 3 of Section A of the Decision envisages that card-issuing institutions shall carry out work on aligning the credit card limits of all cardholders with the maximum credit card limit to be determined within the scope of the provisions of sub-paragraph 1 of Section A of the Decision, and complete this work by January 1, 2027.
4. Data Reporting Obligation
Section B of the Decision introduces an important data reporting obligation for the purpose of monitoring and evaluating the general and individual risk status and limits of card-issuing institutions and credit card customers.
According to this provision, the income amount information taken into account in allocating limits to credit cardholders must be reported by banks to the Turkish Banks Association Risk Center on the day the allocation is made. It is envisaged that the necessary work regarding the collection of this data shall be carried out by the Risk Center.
IV. CONCLUSION
BRSA’s Decision No. 11367 dated January 29, 2026 introduces two fundamental regulations regarding the determination and management of credit card limits. First, monthly or annual average income is taken as the basis in new card issuance and limit increases, and such income is verified only with documents deemed suitable for proving income, and other risk factors are evaluated as supportive elements provided that they do not exceed the maximum limit calculated in this way. Second, a gradual reduction is made in the limits of existing high-limit cardholders. In this context, the limits of cardholders with limits between 400 thousand TL and 750 thousand TL must be reduced by 50 percent of the amount in the period when the available limit was at its lowest, taking into account the period from January 2025 to the last account cut-off date before the Decision date; the limits of those with limits exceeding 750 thousand TL must be reduced by 80 percent, and limit reduction transactions must be completed by February 15, 2026. The final date of January 1, 2027 has been set for aligning all cardholders’ limits with the new criteria. Additionally, banks are obligated to report the income information used in limit allocation to the Turkish Banks Association Risk Center.
B. KEY TAKEAWAYS
(1)The regulation is intended to fulfill the duties assigned to BRSA within the scope of the Action Plan for Combating Illegal Betting, Games of Chance and Gambling in Virtual Environment, which entered into force with the Presidential Circular dated October 31, 2025.
(2)In the issuance of new credit cards and limit increases, monthly or annual average income is taken as the sole determining criterion, and income verification can only be made with documents suitable for proof.
(3)Factors such as impediment status, economic and social status, scoring system results can be evaluated as complementary elements provided that the income-based maximum limit is not exceeded.
(4)Approximately 75 percent of Türkiye’s 40.7 million credit card users have limits below 400 thousand TL, and 90 percent have limits below 750 thousand TL.
(5)79 percent of the total 13.3 trillion TL individual credit card limit is not being used, only 21 percent is actively used.
(6)The limits of cardholders with limits between 400,000 TL and 750,000 TL will be reduced by an amount corresponding to 50%, while the limits of those with limits exceeding 750,000 TL will be reduced by an amount corresponding to 80%.
(7)In limit reduction, the amount in the period when the available limit was at its lowest during the period from January 2025 to the last account cut-off date before the Decision date is taken as the basis.
(8)If the existing available limit as of the limit reduction transaction date is less than the limit to be taken into account in the calculation, the reduction will be calculated based on the existing limit.
(9)For cardholders whose limits fall to 400 thousand TL and below after limit reduction, income documentation will not be required for limit increase requests up to 400 thousand TL.
(10)The final date of January 1, 2027 has been set for aligning all cardholders’ limits with the new criteria, and this process envisages a transition period of approximately one year.
