Türkiye has introduced a new framework governing payments and asset recovery for certain investment funds ordered into liquidation. Law No. 7596 on Certain Investment Funds Ordered into Liquidation was published in the Official Gazette on 27 October 2026. On the same day, the Capital Markets Board of Türkiye, or SPK, issued Decision No. 76/1903 setting out the operational rules for liquidation and payments.
The law does not create a general or permanent liquidation regime for every investment fund. Its scope is limited to funds that the SPK ordered into liquidation on 17 September 2026 and whose liquidation had not been completed when the law was published. According to the SPK, the implementation covers funds established by Tera Portfolio Management, Pusula Portfolio Management and Atlas Portfolio Management.
One million liras is a ceiling, not an automatic payment
The law and the SPK rules allow interim payments to be made to unit holders on a fund-by-fund basis. However, one million Turkish liras is not a guaranteed flat payment for every investor. It is an upper limit. An interim payment cannot exceed either the investor’s net invested amount, calculated by the Central Securities Depository without indexation, or one million liras. For funds other than money-market funds, the value of the investor’s units at the relevant calculation date also limits the payment.
If a fund’s distributable cash is insufficient to meet all interim-payment obligations, the available resources may be allocated in an established order. Subject to SPK approval, the liquidating institutions may use a sequence designed to reach the largest possible number of investors or propose a minimum interim amount applicable to all eligible unit holders. If a fund has enough distributable cash to cover the full amount calculated using the pre-liquidation unit price, a final payment may be made instead of an interim payment.
Money-market funds receive priority
The SPK said payments would begin with funds whose names contain the term “money market.” For other funds, the payment order will take into account the ratio of distributable cash to the total interim-payment obligation. Where funds have the same or similar coverage ratios, priority may be given to the fund for which the available cash can cover payments to the greatest number of investors.
Ziraat Bank will conduct the liquidation of funds established by Pusula Portfolio and Atlas Portfolio. Türkiye İş Bankası will handle funds established by Tera Portfolio. The process will be coordinated by the SPK in cooperation with the Savings Deposit Insurance Fund, Borsa Istanbul, the Central Securities Depository, Takasbank, the banking regulator and other relevant institutions.
Fund units remain in place during interim payments
Any interim payment will be deducted from the investor’s eventual liquidation balance. Fund units will not be returned or cancelled at the interim-payment stage; their return will take place during the final liquidation payment. The law also allows separate recovery accounts to be established for each fund at the Savings Deposit Insurance Fund. These accounts may hold assets recovered after being unlawfully removed from a fund and amounts collected from parties held responsible for losses.
Payments will not be made from liquidation or recovery accounts to people or institutions that the SPK determines committed, or acted together in committing, specified capital-market violations and reports to the relevant institutions through the Central Securities Depository. The rule means that the payment mechanism is not unconditional for every person recorded in connection with the funds.
What investors need to monitor
Eligibility will be established by reconciling the records of the Central Securities Depository with those of the institution responsible for liquidation. A fund’s inclusion in the process therefore does not by itself guarantee a payment on a specific date or in a specific amount. The result depends on the investor’s net investment, the fund’s liquid resources, the applicable calculation date and the distribution method approved by the SPK.
The SPK announcement did not provide one definitive payment date applying to all eligible unit holders. Investors therefore need to follow official notices concerning their particular fund, calculation, payment order and responsible bank. The framework is not investment advice and does not promise recovery of a specific amount. It establishes the legal and administrative method for identifying eligible claims, managing available assets and making interim or final payments in these particular liquidation proceedings.
