New Licensing and Capital Requirements for Insurance Support Services Providers in Türkiye

The Regulation Amending the Regulation on Insurance Support Services (the “Regulation”), published by the Insurance and Private Pension Regulation and Supervision Authority (“IPRSA”), was published in the Official Gazette No. 33318 dated 23 July 2026 and entered into force on the same date.

The amendments significantly reshape the regulatory landscape for insurance support services, in particular by introducing authorization and capital regime for claims management and assistance services providers, setting out a dedicated framework for claims investigators and drawing clear lines between support service providers and insurance intermediaries.

1. Support services requiring authorization from IPRSA

Pursuant to the amendments to the Regulation, (i) service providers that supply companies with the full range of services consisting of receiving claim notifications, opening claim files on the company’s system, requesting information and documents from claimants and assessing claims; and (ii) service providers that offer companies support services for policyholders or beneficiaries in the form of emergency assistance, roadside assistance and home or workplace assistance on a 24/7 basis upon the occurrence of the insured risk, are required to obtain authorisation from the IPRSA to perform such services.

In addition to the specific amendments introduced for claim management, 24/7 assistance and claim investigation activities within the scope of the Regulation, other insurance support services regulated under the insurance legislation will continue to be subject to the existing principles and procedures set out therein.

2. Clear separation between support service providers and insurance intermediaries

With the amendments introduced to the Regulation, the status of support services providers within the management and supervisory structures of insurance companies, insurance intermediaries and loss adjusters has been redefined. In particular:

• Persons who are involved in the management or supervision of insurance companies, insurance agents, insurance brokers and loss adjusters, as well as those who are authorised signatories on their behalf, may not serve on the boards of service providers, may not act as authorized signatories for such entities, may not become shareholders thereof and may not accept any remunerated work from them. These restrictions are not applicable to support service providers which are controlled by insurance companies (or any of their affiliates), except for the restriction relating to shareholding.
• Natural and legal persons providing support services within the scope of the Regulation may not engage in insurance intermediation activities, and natural and legal persons engaged in insurance intermediation activities may not provide support services.

These amendments are designed to ensure a clear functional and organisational separation between distribution and support services activities, and to mitigate conflicts of interest. Furthermore, the IPRSA has been expressly authorized to require support services providers to take out professional liability insurance or provide other forms of security.

3. Eligibility criteria for claims management, assistance providers and claims investigators

Providers intending to carry out activities that are now subject to authorization must be incorporated as joint stock companies with their registered seat in Türkiye. They are also required to have suitable premises, adequate technical and systems infrastructure, appropriate administrative set-up and sufficient human resources to be able to perform their functions properly.

Equity requirement and shareholders

For these entities, a minimum equity level of TRY 250 million has been introduced. The IPRSA may, in view of the size and characteristics of the business they conduct with insurers, lower this threshold by up to 50% or increase it by up to 100%. Unless the IPRSA decides otherwise, the minimum equity requirement will be adjusted each year at the beginning of the calendar year in line with the domestic producer price index announced by the Turkish Statistical Institute. Founders must not be bankrupt or subject to concordat (insolvency composition) proceedings, must have the financial capacity and reputation appropriate for a founder or shareholder and must not have been convicted of the offences listed in Insurance Law No. 5684. The same fitness and propriety criteria apply to shareholders who, directly or indirectly, hold 10% or more of the capital, voting rights or usufruct rights, as well as to holders of privileged shares that allow them to exert influence over management even if their formal shareholding remains below this level.

Authorization

Before starting to provide services, such entities must obtain authorization from the IPRSA and subsequently be included in the list maintained by the Insurance Information and Monitoring Centre. If, after authorization has been granted, the underlying conditions are no longer met or breaches of the applicable rules are not remedied within the period set by the IPRSA, the latter may temporarily suspend the provider’s activities or revoke its authorization. In addition, any direct or indirect transfer of shares that results in a holding reaching, exceeding or falling below 10%, 33% or 50% of the share capital is now subject to the IPRSA’s prior approval.

Claim investigation

Claim investigation work carried out by persons other than an insurer’s own employees is likewise brought under the IPRSA’s authorization regime. Individuals seeking to act as claims investigators must be resident in Türkiye, must have successfully completed a higher education programme of at least two years, must have acquired a minimum of two years’ experience in claims-related functions within the insurance sector and must complete, with success, the training programme delivered by the Insurance Training Centre.

Legal-entity claim investigators must have their registered office in Türkiye, and their authorized representatives and shareholders are required to meet the financial soundness and clean-record criteria laid down in the Regulation. Moreover, those who are empowered to represent and legally bind the legal entity in respect of claim investigation activities must themselves be natural person claim investigators holding an authorization issued by the IPRSA.

In performing their functions, claim investigators are expected to ground their assessments in specific and verifiable information and documentation. Where it is determined that an investigator has failed to carry out the necessary inquiries, has intentionally rendered a one-sided opinion or has behaved in an unduly accusatory manner towards the parties concerned, the IPRSA may withdraw that investigator’s authorization.

4. Phased transition schedule for existing providers

A phased transition schedule has been introduced to facilitate the adaptation of entities already active in the sector to the new regime. Existing companies will be required to increase their capital to at least 25% of the prescribed minimum amount by 31 December 2026, to at least 50% by the end of 2028 and to the full minimum amount by 31 December 2030. They will have until the end of 2028 to convert into a joint stock company, while existing claim investigators will have until 31 December 2026 to satisfy the new education and experience requirements. Claim investigators who can document that they are currently providing services to insurance companies will be exempt from the higher education requirement.

CONCLUSION

Overall, the amended framework materially tightens the conditions under which insurance support services may be outsourced in Türkiye, both by bringing key activities under an IPRSA authorization regime and by imposing stringent requirements on governance, capital, shareholding structures and individual qualifications. In this new environment, insurers will need to map their current and planned support arrangements against the scope of the Regulation, reassess the eligibility of existing providers and reflect the revised allocation of regulatory responsibilities and risks in their outsourcing contracts, while support service providers and claim investigators should promptly assess whether they can meet the new licensing, capital and fit-and-proper standards within the applicable transition periods and, where necessary, prepare and file authorization applications with the IPRSA.