The Capital Markets Board (SPK) Has Revised the Minimum Capital Requirements for Portfolio Management Companies for 2027

The Capital Markets Board (SPK) Has Revised the Minimum Capital Requirements for Portfolio Management Companies for 2027

Pursuant to Decision No. 52/1589 dated August 28, 2026, published in the Capital Markets Board’s (“SPK”) Bulletin No. 2026/54 dated August 29, 2026, and in accordance with the first paragraph of Article 41 of the Communiqué No. III-55.1, “Communication on Portfolio Management Companies and the Principles Governing Their Activities” (“PYŞ Communication”), the minimum capital amounts applicable for the year 2027 have been revised.

Accordingly, the initial capital specified in Article 5, paragraph 1, subparagraph (c), of the PYŞ Communiqué and the minimum paid-in capital amount specified in Article 28, paragraph 4, of the same Communiqué will be 500,000,000 TL for portfolio management companies with broad authority, and 250,000,000 TL for portfolio management companies with limited activities.

The decision sets the capital threshold required for entry into the sector for newly established portfolio management companies, as well as the minimum capital standard that existing companies must maintain, at the same levels for the year 2027. In this regard, the regulation has the potential to directly impact scale, capital planning, and business models within the portfolio management sector.

Basic Framework of the Regulation

• Full-service portfolio management companies: 500,000,000 TL in initial capital and 500,000,000 TL in minimum paid-in capital.

• Portfolio management companies with limited operations: 250,000,000 TL in initial capital and 250,000,000 TL in minimum paid-in capital.

• The new amounts will take effect in 2027.

Sectoral Impacts

1. The capital threshold for entering the sector is increasing

The requirement for a higher equity capacity for newly established portfolio management companies will increase entry costs and the need for initial financing, particularly for companies with broad authority. While this will encourage new entrants to be established by partners with stronger capital structures, it will also lead smaller-scale ventures to reassess their decisions regarding establishment and the scope of their operations.

2. Capital planning by the end of 2026 is becoming increasingly important for existing companies

Portfolio management companies currently in operation will need to determine in advance the difference between their existing capital and the required amounts, taking into account the new minimum paid-in capital thresholds to be implemented in 2027. For companies with a capital shortfall, it is of the utmost importance to plan—before the end of 2026—the procurement of cash capital from shareholders, the capital increase schedule, corporate approval processes, and the necessary notifications and permits.

3. The trend toward economies of scale and industry consolidation may strengthen

Higher equity requirements may put pressure on return on equity, particularly for companies with relatively small managed portfolio sizes and revenue bases. Consequently, it is expected that small and medium-sized companies will increasingly consider alternatives such as bringing in new partners, strengthening their capital structure, forming partnerships, or pursuing mergers and acquisitions. This effect is not a direct consequence of the regulation but rather a likely sectoral reflection of the increase in the cost of capital.

4. The economic difference between the broad-authority and limited-activity PMC models is becoming more pronounced

The fact that the minimum capital requirement for companies with broad authority is twice that of companies with limited scope of operations highlights the impact of the scope of operations on the cost of capital. Companies will need to evaluate the commercial contribution of their broad scope of authority, the size of their managed portfolios, and their revenue projections in conjunction with the cost of capital; they will also need to reassess the alignment of their scope of operations with their corporate strategy.

5. The competitive landscape may shift toward greater capital strength and institutional capacity

While the new capital thresholds may be easier to meet for companies with strong partnership structures and large managed portfolios, they could create relatively higher costs for smaller-scale companies. Consequently, competition is expected to be shaped not only by products and performance but also by equity strength, corporate infrastructure, and long-term financing capacity.

6. Financial resilience and investor protection may be strengthened

Raising the minimum capital requirement will support portfolio management companies in operating with a stronger financial structure to withstand operational risks, investments in technology and human resources, and extraordinary market conditions. In this regard, the regulation can be viewed as a precautionary measure aimed at strengthening the sector’s financial resilience and corporate structure.

7. Capital requirements may increase alongside the hedge fund regulations issued on the same date

Under the amendments made to the Guide on Investment Funds by the same Board Decision dated August 28, 2026, an additional requirement has been established for certain portfolio management companies: if more than 50% of the average monthly managed collective portfolio size consists of hedge funds, the issued capital must be increased by 10% in cash. Therefore, it would be appropriate for companies with a heavy focus on hedge funds, in particular, to evaluate their 2027 minimum capital requirements not in isolation from this additional capital requirement, but as part of a comprehensive capital planning process.

Recommended Actions for Portfolio Management Companies

• Determine, on a company-by-company basis, the difference between the current paid-in capital and the minimum amount projected for 2027,

• If necessary, scheduling a cash capital increase by taking into account shareholders, the board of directors/general assembly, and registration processes,

• Re-evaluate the scope of operations in companies with broad authority, taking into account the size of the managed portfolio, revenue structure, and cost of capital,

• Taking into account the impact of the additional equity requirement on targeted growth and profitability indicators in the 2027 budget and business plans,

• Separately calculating any additional capital requirements that may arise from the Guide amendments effective on the same date for companies with a high proportion of hedge funds.

Conclusion

The CMB’s Decision dated August 28, 2026, is a significant regulation that strengthens the sector’s financial resilience by establishing a higher minimum capital standard for portfolio management companies effective in 2027. The regulation is expected to lead to a reassessment of capital and operational strategies, particularly among smaller-scale companies, an increased emphasis on economies of scale, and a growing competitive advantage for corporate structures with strong capital bases. Therefore, it would be advisable for companies to promptly evaluate their capital adequacy positions and any necessary capital increase processes prior to the transition to 2027.