The Law entered into force on 27 October 2026 and the Capital Markets Board (CMB) adopted its first implementing decision on the same day. This article brings the scattered developments together in one place: in what order payments will come, which rules apply to your fund, which claims can be brought and which dates are the last days. We do not give definitive answers; please consult a lawyer about your own situation.
In brief
- The Law is in force. Law No. 7596 was published in Official Gazette No. 33413 of 27 October 2026, with effect from 17 September 2026. It covers only the funds placed into liquidation by the CMB’s decisions of 17 September. 1 2
- Interim payments will start in the Tera, Pusula and Atlas funds. Funds with “money market” in their name come first; at most TRY 1 million per fund. No payment date has been announced yet. 3
- Not everyone is subject to the same rules. Hedef funds remain outside the interim payment. The other Tera and Pusula funds placed into liquidation on 26 October fall outside the Law altogether. 3 4
- The Law itself cannot be challenged in court, but the decisions implementing it can. The argument that the Law is unconstitutional can be raised in a case brought in time against a CMB decision. 5
- The nearest date is 16 November 2026. It is followed by 27 November, 15 December and 25 December 2026. Damages claims have longer periods, but one of them is only six months (17 March 2027). 6 7
- Bringing a claim does not cost you your liquidation share. The Law contains no bar on litigation; however, any amount you recover through a claim is deducted from the final payment. 2
Where do we stand today?
The CMB decided to liquidate 131 funds of seven portfolio management companies and announced the liquidation procedure. 8
Decisions were adopted on interim payments for the Tera, Pusula, Atlas and Hedef funds and on the order of liquidation for the A1 Capital, Bulls and Pardus funds. 9
The Hedef funds were removed from the interim payment and made subject to the ordinary liquidation rules. 10
The Grand National Assembly adopted the Law. A provision added at the last stage treats investors whose units were blocked under orders given on or before 17 September but not executed as unitholders, not as creditors. 2
The activities of Tera and Pusula were temporarily suspended. İş Bankası and Ziraat Bankası were appointed to liquidate the two companies’ other funds that had not been placed into liquidation on 17 September. No list of funds was published. 4
The Law was published in the Official Gazette and entered into force. On the same day the CMB set out the first procedures and principles based on the Law. 1 3
What happens next?
Read together, the Law and Decision 76/1903 suggest that the process will move in the order below. The CMB has not yet announced any dates.
- Determining who holds whatWho holds how many units in which fund will be determined by reconciliation between the records of the appointed liquidating bank and the Central Registry (MKK). Investors with blocked orders will also be on this list as unitholders. No procedure has yet been set for investors to see their own record and object to it. 2
- Interim payment (Tera, Pusula, Atlas)Funds with “money market” in their name will be paid first. In the other funds, payment starts with the fund whose cash covers its payment obligation at the highest ratio. In each fund, the payment cannot exceed your net investment amount without inflation indexation, the value of your units on the relevant day, or TRY 1 million. If a fund’s cash is enough to pay everyone at the 16 September value, a final payment is made instead of an interim one. 3 2
- A minimum amount if cash is shortWhere cash is insufficient, the CMB may start with the smallest amounts or approve a minimum interim payment for all unitholders. That approval will be announced as a separate decision. 3 2
- Recovering diverted assetsThe CMB will determine the loss and the persons responsible for each fund and notify the Savings Deposit Insurance Fund (TMSF), which will pursue these amounts like public receivables. Assets seized or confiscated in the criminal investigation will go not to the Treasury but to the fund or to the fund’s own recovery account. That account cannot be attached. 2
- Final paymentIf a fund’s cash is not enough to pay everyone at the 16 September value, the final payment will be based on the money you actually put into and took out of the fund, adjusted for inflation (the net investment amount). Interim payments and amounts received by other means will be deducted. Your units will be redeemed at this stage. 2 3
Early leavers and share gains. The Law provides that people who exited a fund before liquidation with returns above inflation may voluntarily return that excess to accounts to be announced by the CMB. These fund-specific accounts and the calculation method have not been announced yet. Only one point has been settled: amounts paid into the general share refund account will first go to money market funds whose interim payments fall short. 2 3
Which group are you in?
| Group | What applies now |
|---|---|
| A Tera, Pusula or Atlas fund liquidated on 17 September with “money market” in its name | First in line for the interim payment. At most TRY 1 million per fund; cannot exceed the non-indexed net investment amount or the 16 September value. No date announced. 3 |
| Other Tera, Pusula or Atlas funds liquidated on 17 September | After the money market funds; the fund with stronger cash comes first. The amount also cannot exceed the value of your units on the day before the payment calculation. 3 |
| Hedef funds | Outside the interim payment; ordinary liquidation rules apply. The Law also applies to these funds, but no separate procedures have been set for them yet. 10 3 |
| A1 Capital, Bulls and Pardus funds | Ordinary liquidation payments are continuing. Decision 76/1903 does not mention these funds; how the Law will apply to them is not yet clear. 11 |
| Tera and Pusula funds placed into liquidation on 26 October | Outside the scope of the Law: the statutory interim payment, inflation indexation and recovery through TMSF do not apply to them. No list of funds has been published. 4 2 |
| Investors who gave a redemption order on or before 17 September and were not paid (blocked units) | Treated as unitholders; they have no priority and will be paid together with the other unitholders. Decision 76/1903 does not address this group separately. More: 17 September orders. 2 |
| Investors with units in more than one fund | The TRY 1 million cap applies separately to each fund. 3 |
You can check which company your fund belongs to and whether it is on the list on the Is my fund on the list? page.
Which claims can be brought?
Liquidation payments arrive automatically; you do not need to sue to be paid. Litigation becomes relevant for two purposes: if you consider the part of a CMB decision applied to you unlawful, or if you want to claim the loss left uncovered after the payment from someone. The details are on the Legal remedies page.
1. Action for annulment of CMB decisions
Administrative courtsAn action for annulment can be brought before the administrative court against the CMB’s liquidation and implementing decisions. The Law itself cannot be challenged directly. However, in a case brought in time against a decision based on the Law, the court can be asked to refer the statutory provision to the Constitutional Court; if the court finds the argument serious, it makes the referral. 5
- Which decisions
- The liquidation decisions of 17 September; the announcement of 28 September cancelling orders and the decisions of 30 September; the decision of 15 October removing Hedef from the interim payment; the decisions in Bulletin 2026/75 of 26 October; implementing Decision 76/1903 of 27 October. A separate period runs for each new decision. 8 12 9 10 4 3
- Where
- As a rule, the court where the authority that took the decision is located, i.e. the administrative courts in Ankara, where the CMB has its seat. The jurisdiction of the Istanbul administrative courts under the Law covers only cases concerning TMSF’s enforcement proceedings. 6 2
- Deadline
- 60 days from publication. The cautious last days are in the calendar below. 6
- Note
- Annulling the interim payment as a whole could work against investors. In most cases the claim should therefore target the part of the decision applied to you or what the decision fails to regulate. The claimant must show that the decision affects their personal interest. Our assessment.
Our assessment: for whom does an annulment action stand out?
- Investors with blocked units: The Law removed their priority and applies retroactively. This is where an argument of unconstitutionality based on the right to property is strongest. 2
- Investors in Hedef funds: Their exclusion from the interim payment was carried into the statutory regime by Decision 76/1903; the decision gives no reasons for this distinction. 3
- Investors in funds with little cash: The ordering of funds by “strongest cash first” is not in the Law; it was introduced by the decision. It affects the timing of payment, not the amount. 3
- Investors in equity funds: Amounts paid into the general share refund account are to be distributed first to money market funds. 3
- Funds that are money market funds in substance but lack the words in their name: The Law refers to the “nature” of the fund; the decision uses the fund’s “name”. 2 3
- Funds placed into liquidation on 26 October: The bulletin states neither the legal basis for the liquidation nor the list of funds; funds of the same company are subject to different regimes depending only on the date of the decision. 4
- Persons placed on the list of those who will not be paid: No payment is made to persons the CMB finds involved in market abuse; no procedure for notifying them or for objection has been set. For a person wrongly placed on the list, this is a separate decision. 3 2
2. Damages action against the CMB (full remedy action)
Administrative courtsThe claim is that the CMB performed its supervisory duty late or inadequately, i.e. a service fault. The Law contains no provision limiting the CMB’s liability. 2
- How
- If the loss arises from an act or omission of the CMB, a written application to the CMB must be made first. After a refusal or 30 days without an answer, a full remedy action is brought within 60 days. If the loss arises from a Board decision, the action can be brought directly or together with an action for annulment. 6
- Deadline
- The application must be made within one year of learning of the loss; cautious last day 17 September 2027. 6
- Note
- The Council of State has dismissed claims on the ground that the loss had not yet materialised while the receivable could still be collected by other means. In a damages action brought while liquidation is ongoing, whether the loss has crystallised will be debated; making the application in time is important to preserve the deadline. 13
3. Against the portfolio management company, custodian, distributor and signatories of fund documents
Private lawThe Law makes the fund’s founding portfolio management company primarily liable for assets unlawfully taken out of the fund and, if recovery fails, the persons identified by the CMB personally liable, and it has these claims pursued by TMSF. This is enforcement on behalf of the fund; investors’ own claims remain possible alongside it. 2
- Against whom
- The founding company 7; the fund’s custodian 7; the bank or brokerage firm that sold you the fund as distributor; those responsible for false or incomplete information in the prospectus and similar documents 7.
- Where
- Commercial court of first instance, with mediation first as a precondition. A retail investor’s claim against the distributor may qualify as a consumer transaction; consumer arbitration committees or consumer courts then come into play. 14 15
4. Criminal investigation
Criminal courtsAs a person harmed by the offence, you can file a complaint with the Chief Public Prosecutor’s Office and, once the case reaches trial, apply to join the proceedings. Under the Law, cash and capital market instruments seized in the investigation will be returned to the fund or its recovery account, and confiscated assets will also be transferred to the fund. The criminal file is therefore one of the main potential sources of compensation. A complaint does not by itself suspend the limitation periods for damages. More: Criminal proceedings. 16 2
“Class actions” and joint petitions. Each investor has their own right and their own deadline for their own loss. In administrative proceedings, several persons whose rights or interests are shared and whose claims arise from the same facts may sue with a single petition. The annulment of a regulatory decision may also benefit non-claimants, because the decision falls for everyone. For damages, however, you must protect your own deadline. 6 Our assessment.
Calendar: last days
The dates assume that each period started at the earliest possible moment. Your period may start later, but do not leave it to the last day.
-
Annulment action against the decision removing Hedef funds from the interim payment
Decision 70/1821 of 15 October was published in the bulletin on 16 October; the 60 days are counted from that date. Because Decision 76/1903 maintains the same distinction, the point can also be raised in a case brought against that decision by 25 December; the cautious course is not to miss 15 December. 10 6
-
Annulment action against the decisions of 26 October (2026/75) and 27 October (76/1903)
For the 27 October decision, the statutory last day may move to 28 December because of the weekend; the cautious target for both is 25 December. The unconstitutionality of the Law can be raised in these cases. 4 3 5
-
Written prior application to the CMB for damages
One year from learning of the loss. After a refusal or 30 days without an answer, an action must be brought within 60 days. 6
New decisions start new periods. A separate 60-day period runs from the publication of every decision the CMB adopts on matters such as the payment date, the minimum interim payment, fund-specific refund accounts or the liquidation procedure for the 26 October funds. New decisions do not extend the earlier periods. All deadlines: Deadlines. 6
What can you do now?
- Identify your groupFind out your fund’s founding company, the fund’s full name and whether you have a blocked order. The table above shows which rules apply to you.
- Gather your recordsPurchase and redemption confirmations, your e-YATIRIMCI statement, order and blocking records, the fund prospectus and correspondence with the distributor. Keep the date of every amount you paid into and withdrew from the fund so you can later check your net investment amount. Checklist: What should I do?
- Keep the receipt if a payment arrivesThe interim payment will be deducted from the final payment. Ask your distributor in writing how the amount was calculated.
- Draw up your calendar16 and 27 November 2026 are the nearest dates; 15 December for Hedef investors and 25 December for the 26 and 27 October decisions. Decide whether to bring a claim before these dates.
- Beware of scamsNobody can move you up the payment queue for a fee; payments are made through the appointed liquidating banks. See Scam warning.
- Consult a lawyerWhich route makes sense for you depends on your fund, when and where you bought it, the status of your orders and the payment you will receive.
What is not yet known
- The date on which interim payments will start, and the minimum interim payment. 3
- The list and number of funds placed into liquidation on 26 October, and the legal basis for their liquidation. 4
- A procedure for investors to see and object to their own unitholding and net investment record. 2
- The fund-specific voluntary refund accounts for early leavers and the calculation method. 2
- How the Law will be applied to the A1 Capital, Bulls, Pardus and Hedef funds.
- The tax treatment of the payments.
For an article-by-article assessment of the Law see Law No. 7596 analysis; for the details of the interim payment see Interim payment.
Sources
- Alomaliye, 27 October 2026: Law No. 7596 published in the Official GazetteReport that Law No. 7596 was published in the Official Gazette of 27 October 2026, No. 33413, and entered into force (CNBC-e, Karar and Memurlar.net reported the same on the same day). We could not open the Official Gazette issue itself; the authoritative text is the Official Gazette text.
- Law No. 7596 on Certain Investment Funds Placed in LiquidationAdopted on 22 October 2026; Official Gazette of 27 October 2026, No. 33413. Entered into force on publication, with effect from 17 September 2026 (art. 8/1). The link is to the adopted text as published by the TBMM.
- SPK Bulletin 2026/7627 October 2026. Decision No. 76/1903 of the Board’s decision-making body dated 27 October 2026: procedures and principles for the liquidation and payments to be made under Law No. 7596 (11 items). Commencement of liquidation under the Law for the Tera, Pusula and Atlas funds placed in liquidation on 17 September 2026 (item 1); the banks in charge (item 2); interim payment under art. 4/2-3 of the Law and within the framework of the decisions of 30 Sept and 15 Oct (item 3); funds whose name includes “money market” first (item 4); final payment instead of an interim payment where cash suffices (item 5); per-fund cap and the limits applying where cash is insufficient (item 6); order for the other funds (item 7); ordering and a minimum amount (item 8); no payment to persons within art. 3/6 of the Law (item 9); unit redemption and set-off (item 10); distribution of the general share return account (item 11). No payment date. (Text checked against the PDF of the bulletin, 27 Oct 2026.)
- SPK Bulletin 2026/7526 October 2026. The capital market activities of Tera Portföy Yönetimi AŞ and Pusula Portföy Yönetimi AŞ were temporarily suspended under art. 97/1 of the Capital Markets Law; Türkiye İş Bankası (Tera) and T.C. Ziraat Bankası (Pusula) were assigned to liquidate the investment funds founded by these companies other than those placed in liquidation by the decisions of 17 September 2026, together with their real estate investment funds and venture capital investment funds. The bulletin contains no list or number of these funds and no liquidation procedure. (Text checked against the PDF of the bulletin, 27 Oct 2026.)
- Constitution of the Republic of Türkiyeart. 125: The administration is obliged to pay for the loss arising from its own actions and decisions. art. 152: The courts’ route for referral to the Constitutional Court.
- Administrative Procedure Act No. 2577 (İYUK)art. 7: time limit for filing suit (60 days in the administrative court). art. 11: optional application to the authority that took the decision before filing suit; it stops the time limit for suit, and 30 days without a response is deemed a rejection (reduced from 60 to 30 days in 2021 by Law No. 7331). art. 12: for loss arising from an administrative decision, a full remedy action either directly or together with an annulment action. art. 13: for loss arising from an administrative action, the requirement to apply to the administration first (within 1 year of learning of it and in any event within 5 years; 30 days without a response is deemed a rejection). art. 15/1-e: in an action filed without the prior application, the petition is sent to the administration.
- Capital Markets Law No. 6362 (SPKn)The text of the law in force. The relevant articles are indicated separately on each page.
- SPK Bulletin 2026/6117 September 2026. Decision No. 57/1708: the liquidation procedures and principles (paragraph A), suspension of transactions outside TEFAS (B), the current list of 131 funds (C).
- SPK Bulletin 2026/6730 September 2026. Decision No. 64/1770 (order of liquidation for the A1 Capital, Bulls and Pardus funds) and Decision No. 64/1775 (interim payment for the Tera, Pusula, Atlas and Hedef funds).
- SPK Bulletin 2026/7016 October 2026. Decision No. 70/1821 of the Board’s decision-making body dated 15 October 2026: the funds founded by Hedef Portföy Yönetimi A.Ş. were removed from the scope of interim payment decision No. 64/1775; their liquidation will follow the principles set by decision No. 64/1770 for the A1 Capital, Bulls and Pardus funds. (Content checked against the official statement and press reports, 19 Oct 2026.)
- Directorate of Communications statement, 18 October 2026: Sixth Fund Board MeetingIn-kind and cash liquidation transactions of approximately TRY 40.8 billion completed by Ziraat Bank for more than 45,000 people in 66 funds of A1, Bulls and Pardus Portföy; funds in liquidation down from 131 to 65; Hedef funds made subject to the same principles by the SPK decision of 15 October 2026; payments, starting with money market funds, planned for the coming week; the Bill expected to be debated in the General Assembly. (Reported by CNBC-e.)
- SPK Press Release, 28 September 2026Cancellation of the orders transmitted to TEFAS on 17 September 2026, and payment to the holders of those orders from the liquidation balance in proportion to their units.
- Kutlu Gürsel, Meltem, “Sermaye Piyasası Kurulu’nun Denetimi” (Review of the Capital Markets Board)Conference paper, pp. 493-554. It reports the decisions of the 10th Chamber of the Council of State on service fault actions against the SPK (pp. 520-522). The official texts of the decisions are being separately verified.
- Turkish Commercial Code No. 6102 (TTK)art. 5/A: In commercial actions for receivables and damages whose subject is the payment of a sum of money, having applied to a mediator is a precondition to filing suit.
- Consumer Protection Law No. 6502 (TKHK)art. 3: definitions of consumer and consumer transaction. art. 49: every kind of banking service, including investment services, is a financial service. art. 68: mandatory application to the consumer arbitration committee in disputes below the monetary threshold. art. 73: the court with subject-matter jurisdiction in consumer transactions is the consumer court; exemption from court fees. art. 73/A: mediation as a precondition to filing suit in the consumer courts.
- Criminal Procedure Code No. 5271 (CMK)art. 158: reporting an offence and complaint. art. 234: the rights of the person harmed by the offence during the investigation stage. art. 237: joining the public prosecution as an intervening party.
Have a question?
These articles are general information. You can send questions about your own situation through the contact section or by e-mail.
Av. Dr. Mustafa Aykanat · Ankara Bar Association Reg. No 43042 · Yenimahalle, Ankara