Amendments to the Communiqué on Procedures and Principles Regarding the Fees that Banks Can Charge Their Commercial Clients
The procedures and principles regarding the fees that banks can charge to their commercial clients have been amended by the Communiqué (No: 2025/24) (the “Communiqué”), which was published in the Official Gazette dated 18.09.2025 and numbered 32568. This Communiqué amends the Communiqué on the Procedures and Principles Regarding Fees that Banks Can Charge Commercial Clients (No: 2020/4).
The Communiqué, which will come into effect on 01.11.2025, lays down new provisions regarding arrangement fees and utilization fees that banks classify under two distinct sub-categories and that may be charged by the banks to their commercial clients. Moreover, the Communiqué introduces certain amendments with respect to merchant fees that businesses must pay when they accept electronic payment methods, such as credit cards or debit cards:
Arrangement Fee and Utilization Fee
The Arrangement Fee is the fee payable by the borrower to the arranger on signing the loan agreement, usually calculated as a percentage of the amount of the loan that was made available (cash and non-cash) to the borrower. The Utilization Fee is a banking fee generally levied in respect of the utilization of credit limits and is calculated on a percentage basis over the cash amount disbursed under the credit limit. The maximum rates applicable to such fees are stipulated separately in the legislation for consumers and for commercial clients.
The provisions governing the arrangement and utilization fees that banks may charge to their commercial clients were first introduced in 2020, and, under the regulation enacted at that time, the maximum arrangement fee rate was set at five per thousand (0.5%) of the allocated credit limit. During the 2020–2025 period, this cap was reduced gradually and, under the Communiqué, was lowered to 0.20%. Utilization fees have been varying between 1 and 1.10% over the years, and the Communiqué has just standardized the rate to 1.10% for all cash loans. This last development has resulted in a contraction in banks’ fee income derived from arrangement fees, whilst constituting a more favorable arrangement, lowering borrowing costs, for borrowers.
Merchant fees
Under the Communiqué, the existing provision on non-instalment purchases of goods and services has been confined to credit-card transactions; moreover, a maximum merchant fee of 1.04% has been set for purchases made by debit card. It is further stipulated that the regulatory rules and limitations applicable to debit-card transactions shall likewise apply to prepaid cards.
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