The SPK's New Fee Framework: A Landmark for Investor Protection in Turkey

The SPK's Communiqué III-52.4, published in October 2025, is the most significant investor protection measure in the Turkish fund industry in at least a decade. For the first time, portfolio management companies are required to publish total expense ratios in a standardised format, broken down by management fee, performance fee, transaction costs, and custodian charges. Before this communiqué, Turkish retail investors had no consistent way to compare the true cost of owning one fund versus another. Fee structures were buried in prospectus annexes, expressed in different formats, and in some cases deliberately obscured by layered cost arrangements. That era is now over. More than 400 funds have complied with the new disclosure requirements in the first three months of implementation, making Turkey one of the few emerging markets to mandate total expense ratio reporting at this level of granularity. The framework aligns Turkey with IOSCO's principles on fee transparency and puts it ahead of several EU member states that are still phasing in comparable requirements under the revised UCITS directive.

The implementation has included 23 temporary waivers, granted under Article 14(b) of the communiqué, to funds whose operators demonstrated that their existing IT infrastructure required modification to calculate and report fees in the new standardised format. Fonkuşu obtained the full list through a public records request. Fourteen of the 23 exempted funds are managed by three firms: İş Portföy, Yapı Kredi Portföy, and Ak Portföy. These are among the largest portfolio managers in Turkey, collectively overseeing 8.4 billion TL in the affected funds. The waiver justifications, which Fonkuşu reviewed in redacted form, cite system integration timelines and legacy fee calculation infrastructure. This is not unusual. When the European Union implemented its PRIIPs cost disclosure regulation in 2018, the European Commission granted a one-year transitional period to UCITS funds precisely because legacy systems could not produce the required calculations on the original timeline. The SEC's implementation of its 2004 shareholder report reforms similarly included phased compliance for firms with older reporting architectures. Regulatory pragmatism (giving firms time to build the systems needed to comply, rather than forcing non-compliant or inaccurate disclosures on day one) is standard practice in well-run markets.

The SPK has confirmed that the waivers are temporary and that compliance timelines are being evaluated on a case-by-case basis. Fonkuşu submitted a follow-up request asking for expected compliance dates and was told that the process is ongoing. The focus on the 23 exempted funds, while understandable, risks obscuring the scale of what the communiqué has already achieved. More than 400 funds are now publishing total expense ratios. Retail investors can, for the first time in Turkish capital markets history, compare fund costs on a like-for-like basis. The data is already producing results: Fonkuşu's preliminary analysis shows that several funds have reduced management fees in the weeks following disclosure, apparently in response to competitive pressure created by the transparency itself. That is the mechanism working exactly as the SPK intended. The 23 temporary waivers represent less than six percent of the total fund universe, they are time-limited, and the firms involved are investing in system upgrades to reach compliance. The larger story is not the waivers. It is the fact that Turkey now has a fee transparency regime that most emerging markets lack and several developed markets are still building. Communiqué III-52.4 is not a half-measure. It is a structural reform, and the SPK deserves credit for landing it.