Client Alert:



Significant revisions have been made in the regulations regarding insurance and reinsurance brokerage. The amendment introduce substantial novelties that impact everyone currently involved or intending to enter the sector.

The “Regulation on the Amendment to the Regulation on Insurance and Reinsurance Brokers” (“Amendment”) prepared by the Insurance and Private Pension Regulation and Supervision Agency (“Agency”) which has been published in the Official Gazette on 18/01/2024, introduced significant changes to the Regulation on Insurance and Reinsurance Brokers (“Regulation”). The changes have immediate effect.

Significant Changes

the Amendment provides comprehensive legal protection to the title “broker”. It is explicitly stipulated that no real person or legal entity, other than brokers established in accordance with the legislation, may use words and symbols in their titles or any other documents that may create the impression that they are engaged in brokerage business and transactions. Therefore, the companies that intend to engage in brokerage activities must identify in their title, that they are brokers in the specific branch in which they are licensed.

The qualifications required for legal entities to engage in brokerage activities have been expanded. The requirement for real person brokers “not to have previous conviction for certain crimes” have been extended to also apply to (i) real person shareholders and (ii) real person shareholders of the legal entity shareholders.

Even if employed under alternative titles within the brokers’ internal organization, other managers with powers and responsibilities equal to or greater than the deputy general manager must meet the criteria outlined in the Regulation on general managers and deputy general managers, including professional competence, experience, and a clean criminal record.

With the Amendment, the powers previously granted to the Undersecretariat of Treasury (“Undersecretariat”) have been abolished, and all matters that were within the scope of the authority of the Undersecretariat prior to the Amendment now fall under the authority of the Insurance and Private Pension Regulatory and Supervisory Board, and the Agency.

Moreover, the Amendment authorizes the Agency to temporarily suspend without notice, the brokerage activity of brokers, if the urgency and importance of the situation requires, in order to prevent the rights and interests of the persons involved in the insurance contract from being jeopardized.

Amendments to the Minimum Capital Requirement

With the Amendment, the minimum paid-in capital amount for legal entity brokers has been increased tenfold and the additional amounts to be contributed to the capital have been increased depending on the type of license to be requested. Accordingly:

  • The minimum paid-in capital amount for legal entity brokers has been increased from TRY 250,000 to TRY 2,500,000 (provided it is not less than the amount determined by the Ministry of Trade according to the type of company)
  • The additional contribution to capital for each license request in life and non-life fields of activity, has been increased from TRY 50,000 to TRY 500,000.
  • The additional amount to be contributed to the capital for license requests in the field of reinsurance has been determined as TRY 1,000,000.

In addition, the minimum additional capital contribution for each branch to be established by brokers has increased from TRY 25,000 to TRY 250,000. Unless otherwise determined by the Agency, these amounts will be updated at the rate of increase in the annual domestic producer price index (PPI) announced by the Turkish Statistical Institute in January each year.

The minimum paid-in capital requirements introduced by the Amendment will not apply to existing brokers and real persons and legal entities that have already applied for licenses and branches as of 18/01/2024.

Feel free to reach out to us with any questions or requests regarding the Amendment.

You can access the Amendment in Turkish by clicking on the link provided here.


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