The law on investment funds ordered into liquidation was adopted by the Turkish Parliament on 22 October 2026. Interim payments, indexation, scope and investors' options.
Update (26 October 2026): This article was first published on 20 October 2026, while the regulation was still a bill. The bill was adopted by the Turkish Grand National Assembly (TBMM) on 22 October 2026 and the text has been updated accordingly. As of this update, the law has not yet been published in the Official Gazette.
1. What happened?
On 17 September 2026, the Capital Markets Board of Turkey (SPK) ordered the liquidation of 131 investment funds established by seven portfolio management companies. A criminal investigation concerning these funds is ongoing; there is no final conviction.
The "Bill on Certain Investment Funds Ordered Into Liquidation" was adopted by the TBMM General Assembly on 22 October 2026. According to press reports, it was numbered Law No. 7596, consists of 9 articles and was sent to the Presidency on the same day.
2. When will the law enter into force?
Under the Constitution, the President publishes an adopted law within 15 days; this period ends on 6 November 2026. Press reports expected publication on 27 October 2026, but this is not an official date.
Payments require two steps: publication of the law in the Official Gazette, and the SPK then determining which funds will pay and the payment procedure. No payment date has been announced.
3. Who is covered?
• Funds whose liquidation the SPK ordered on 17 September 2026 and whose liquidation is not completed when the law is published. The law does not create a general liquidation regime for other funds.
• An amendment in the General Assembly extended coverage to investors who gave redemption orders before 17 September that could not be executed because the fund defaulted or no unit price was published. Press reports put this group at about 203,000 investors.
4. How will interim payments be calculated?
• Based on the net investment amount: cash paid into the fund minus cash withdrawn, applying the "first in, first out" rule.
• Investors with a net amount below TRY 1 million may receive that amount; those at TRY 1 million or above may receive up to TRY 1 million.
• The interim payment cannot exceed the unindexed net investment amount.
• If a fund lacks cash, the SPK may set a minimum interim payment; smaller investors may be prioritised.
• Fund units are not returned at the interim stage; interim payments are deducted from the final payment.
5. Final payment and indexation
The final payment will be updated until the liquidation date by the arithmetic average of CPI (TÜFE) and domestic PPI (Yİ-ÜFE) changes. Full payment is not guaranteed if fund assets are insufficient, which is why the recovery mechanism below matters.
6. Who will not be paid?
Persons and entities that the SPK finds to have engaged in market manipulation, insider trading or market fraud, or to have acted together with the funds in such conduct.
7. Liability and the role of TMSF
• Assets unlawfully removed from a fund are treated as fund losses. The portfolio management company is primarily liable; the SPK may also hold other persons personally liable.
• The SPK reports losses and liable persons to the Savings Deposit Insurance Fund (TMSF), which may start collection proceedings. Until these end, no other enforcement proceedings may be pursued against the relevant assets.
• Recovered amounts go into a separate Recovery Account per fund at TMSF, usable only for liquidation and investor payments, and cannot be seized or pledged.
8. Voluntary refunds
Investors who exited the funds with high gains before the SPK decision, and certain shareholders who profited from fund holdings, may voluntarily refund amounts exceeding the inflation-adjusted value.
9. Rights outside the law
The payment scheme does not remove rights under general law. A drop in fund value alone is not grounds for compensation; fault, damage and causation must be shown. Potentially liable parties may include the portfolio management company and its managers, the custodian, the bank or brokerage that sold the fund, and perpetrators of market fraud. Claims beyond principal must be brought within statutory limitation periods.
10. What investors can do now
• Keep trade confirmations, account statements and redemption order records.
• Check Central Registry (MKK / e-YATIRIMCI) records and calculate the net investment amount.
• Follow publication of the law and SPK announcements on the payment procedure.
• Consider filing a complaint or joining the criminal investigation, and monitor limitation periods.
Sources:
• Memurlar.net (Turkish): https://www.memurlar.net/haber/1182116/fon-kanunu-icin-gozler-resmi-gazete-de-sali-beklentisi.html
• Bloomberg HT (Turkish), 22.10.2026: https://www.bloomberght.com/fon-yasasi-kabul-edildi-3792314
• CNN Türk Finans / AA (Turkish), 23.10.2026: https://finans.cnnturk.com/finans-haberler/galeri/son-dakika-fon-yasasi-meclisten-gecti-kapsam-genisletildi-iste-madde-madde-uygulamalar-3483432
• AA / Foreks (Turkish), 21.10.2026: https://www.foreks.com/haber/detay/6ad82d0858b1b941c208de9d/AA/tr/tasfiyesine-karar-verilen-bazi-yatirim-fonlarina-iliskin-duzenlemeleri-iceren-kanun-teklifi-tbmm-genel-kurulunda-21-10-26/
It will be updated once the law is published and the SPK announces the payment procedure. Information on the criminal investigation is as reported in the press; the presumption of innocence applies.
This article is for general information only and does not constitute legal advice. Please consult a lawyer about your specific situation.
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