Updated 28 October 2026. RelocationTR analysis.
For a business owner facing a falling market, the immediate question is whether available cash covers the next payments. A fund holding shown in an app, an entitlement in liquidation and money available in a current account are different things. An expected payout should not automatically become payroll funding.
Different funds follow different payment routes
The Presidency's Directorate of Communications reported on 13 October that payments had already been made for some A1, Bulls and Pardus funds. It linked interim payments for another 65 funds to enactment of a bill before parliament. That announcement does not establish that every fund holder can access their money.
Law No. 7596 was adopted on 22 October and entered into force when published in the Official Gazette No. 33413 on 27 October 2026. It concerns specified funds ordered into liquidation on 17 September whose liquidation was incomplete when the law was published. It is not a general regime for all investment funds.
On 27 October the SPK adopted decision No. 76/1903 and issued guidance for the affected Tera, Pusula and Atlas funds. Ziraat Bankası handles Pusula and Atlas funds; İş Bankası handles Tera funds. Interim payments start with funds whose names include “para piyasası” (money market). Priority does not establish an individual payment date.
How interim payments are calculated
The MKK calculates net investment without indexation. Interim payments are assessed per fund and cannot exceed the net investment amount or TRY 1 million. When distributable cash cannot cover all interim obligations, further limits and different sequencing methods can apply, including an order based on interim amounts or a minimum payment to reach more investors, subject to SPK approval. The cap is not a promise that everyone receives TRY 1 million or a ceiling on final settlement.
If a fund’s distributable cash covers the total calculated from the unit price at the end of the day before the liquidation decision and the eligible units, a final payment is made instead of an interim one. Units are not returned at the interim-payment stage; they are returned during final settlement. The law specifies exclusions for certain persons, which require a separate review.
Case: an asset on the statement, a payment due next week
Suppose a company kept part of its reserve in a fund whose units can no longer be redeemed through the ordinary process. Payroll and a supplier invoice fall due next week. Even if the expected payout covers both amounts, a timing mismatch can still leave the company short of cash.
Show available cash and expected liquidation proceeds separately in the payment calendar. The second line needs a confirmed basis, amount and timing. Where timing is unknown, check whether upcoming obligations can be met without that receipt. This is our liquidity-planning conclusion, rather than a regulatory requirement.
What to request for the actual holding
- The exact fund code, unit balance and ownership statement: does the company hold the asset, or does a shareholder hold it personally?
- The applicable decision and the organisation handling liquidation or payment.
- The reconciliation status, calculation basis and confirmation that the announced procedure covers this fund and holder.
- Outstanding documents, restrictions and a confirmed transfer date, if one has been assigned.
Take these questions to the servicing institution and the adviser reviewing the company's records. A general payout announcement cannot answer them for a particular holding. Equally, a falling stock index does not itself establish an account freeze or a loss in every fund.
Official sources
Checked on 28 October 2026: SPK decision and guidance of 27 October; TBMM text of Law No. 7596; Fund Coordination Board statement of 13 October. Confirm conditions and timing for the specific fund and holder.