Amendments to the Use of Public Disclosure Platform Membership of Crypto Asset Service Providers Have Been Published

With the General Letter No. 1055 dated 12 December 2025 published by the Merkezi Kayıt Kuruluşu A.Ş. (Central Securities Depository) (“MKK”), a User Certificate requirement was introduced for Public Disclosure Platform (“PDP”) users, and regulations regarding the PDP membership of crypto asset service providers were included into the Directive on PDP Membership and the Submission of Disclosures to PDP (“Directive”).

Pursuant to the approval of the Capital Markets Board (“CMB”) dated 25 September 2025, within the scope of the amendments made to the Directive, it has become mandatory for individuals defined as users in the PDP system to hold a PDP User Certificate.

The PDP User Certificate will be obtained following the completion of an online training to be provided by the Sermaye Piyasası Lisanslama Sicil ve Eğitim Kuruluşu Anonim Şirketi (Capital Markets Licensing Registry and Training Agency) (“SPL”) regarding public disclosure regulations and the use of the PDP system, and such training will be conducted by SPL as of 15 December 2025.

Furthermore, as of 15 June 2026, individuals who do not hold a PDP User Certificate will not be eligible to be defined as new users in the KAP system. If users who are already registered in the PDP fail to obtain a PDP User Certificate by this date, their authorizations within the PDP system will be revoked and they will no longer be able to access the system. PDP User Certificates are valid indefinitely, and users are required to complete the relevant training only once.

In addition, in line with the regulations requiring crypto asset service providers to fulfill their public disclosure obligations through the PDP, provisions regarding the PDP membership of crypto asset service providers have been incorporated into the Directive. Accordingly, crypto asset service providers are required to obtain an operating license from the CMB in order to establish PDP membership. In the event that the operating licenses or authorization certificates of such entities are revoked by the CMB, their PDP memberships will be terminated directly by the MKK.

The full text of the Directive can be accessed via this link, and the full text of the General Letter can be accessed via this link.