The Communiqué on Data Sharing Regarding Payment and Electronic Money Institutions Has Been Amended

Significant amendments have been introduced to the Communiqué on Information Systems of Payment and Electronic Money Institutions and Data Sharing Services in the Field of Payment Services by Payment Service Providers (“Communiqué”) through the “Communiqué Amending the Communiqué on Information Systems of Payment and Electronic Money Institutions and Data Sharing Services in the Field of Payment Services by Payment Service Providers” (“Amendment Communiqué”), which was published in the Official Gazette dated 28 March 2025 and numbered 32855.

The Regulation Amending the Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers was also published in the Official Gazette concurrently. You can access our article on this regulatory amendment here.

I.Expansion of the Definition Scope
The scope of the definition of “Account Service Provider” (“ASP”) set forth under Article 3, paragraph 1, subparagraph (cc) of the “Communiqué” has been expanded.

The definition of ASP is no longer limited solely to institutions with which a payment account is held; it now also includes:

• Payment service providers that are obliged to connect to the BKM API Gateway and establish the required technical infrastructure,
• Payment service providers that are participants in the Instant and Continuous Transfer of Funds System (FAST),
• Payment service providers that are not participants in the FAST system yet rank among the top ten based on their annual payment volume.

II.  Amendments to the Transitional Provisions
The Amendment Communiqué also revises paragraph two of Provisional Article 1 of the Communiqué, setting out updated provisions concerning the transition period within its scope.

• Pursuant to the Amendment Communiqué, in addition to payment service providers that hold payment accounts, those participating in the FAST system are also required to comply with the obligations stipulated under Article 24 of the Communiqué by 31 December 2025, effective from the date the provision enters into force.
• Pursuant to paragraph nine, introduced into Provisional Article 1 through the Amendment Communiqué, payment service providers that are not participants in the FAST system but hold payment accounts, offer direct online access to their customers, and rank among the top ten institutions by payment volume as of 2024, will also be required to fulfill their obligations by 31 December 2025.
• Payment service providers that do not fall within the aforementioned scope but are ranked among the top ten institutions in terms of payment volume in subsequent years are required to fulfill the relevant obligations by the end of the calendar year in which they attain such ranking.

The Amendment Communiqué entered into force on 28 March 2025. You may access the full text of the Amendment Communiqué here.