When you deposit into a katilma hesabi, who verifies that the bank's side of the bargain, interest-free deployment into permissible financing, actually happens? In Turkey the answer is a three-layer system: a binding regulation, a scholar committee at every bank, and a sector-wide central board. It is more institutionalized than most savers realize and less transparent than it should be, and knowing how it works tells you exactly what to look for when choosing a bank, because the differences between institutions on this dimension are real and, unusually for the sector, mostly visible if you know where to look.
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Layer 1: The BDDK's 2019 communique
The foundation is regulatory, not voluntary. The BDDK's 2019 Communique on Compliance with Interest-Free Banking Principles and Standards obliges every participation bank to establish an Advisory Committee (danisma komitesi), staff it with qualified members, and operate compliance processes that run through it. This is why every one of the nine retail banks, and both pre-launch entrants once they open, has a committee: it is a license condition under Turkish banking law, not a marketing choice a bank could quietly drop. The communique turned what had been house practice since the 1980s into supervised infrastructure, examinable by the same regulator that audits capital and liquidity.
Layer 2: The bank committees, and who actually sits on them
Each committee reviews and approves products, rules on compliance questions, and issues the bank's internal fatwas. The benches are senior and, notably, interlocking: Prof. Dr. Isak Emin Aktepe chairs Turkiye Finans' committee and deputy-chairs Vakif Katilim's; Prof. Dr. Necmettin Kizilkaya serves Albaraka Turk and Ziraat Katilim; Prof. Dr. Murteza Bedir chairs at both Vakif Katilim and Dunya Katilim; Mehmet Odabasi chairs Ziraat's committee and serves Kuveyt Turk's, which is itself chaired by Prof. Dr. Mohammad Altabtabaei, chairman of the Kuwait Finance House Shariah Board. Hayat Finans adds the sector's most striking appointment: its chair, Dr. Mustafa Dereci, formerly ran the BDDK's own Participation Banking Department. The concentration cuts both ways: consistent standards across banks, but fewer genuinely independent second opinions between them.
Layer 3: The TKBB Central Advisory Board
Above the bank committees sits the Central Advisory Board of the TKBB, the participation banks' association, which issues sector-wide standards that bind every member's committee. This is the layer that keeps one bank's scholars from quietly diverging on what a murabaha or a profit pool may look like. Vakif Katilim gives the layer its most concrete retail expression: it publishes a customer dispute escalation path, if you believe a product violates participation principles, your complaint can run past the bank's own committee to the TKBB central board, with 30-day decision windows. No other bank writes that right down, and we consider it the single best governance artifact in the sector.
What the banks actually publish, compared
| Bank | Committee roster | Beyond the roster |
|---|---|---|
| TOM Bank | Published (Atar, Turan, Gayretli) | Per-product icazet certificate, unique in Turkey; 24 meetings in 2025; dedicated compliance directorate |
| Emlak Katilim | Published (Donduren, Sarac, Topal) | Meeting and decision counts published: 38 meetings, 72 decisions in 2024; annual compliance opinion |
| Vakif Katilim | Published (Bedir, Aktepe, Karaman) | Customer dispute escalation to TKBB with 30-day windows; twice-yearly joint audit meetings |
| Ziraat Katilim | Published with biographies | Full disclosure culture extends to TMSF fine print and ratio locks |
| Kuveyt Turk | Published with biographies | KFH group Shariah heritage; chaired by the KFH board chairman |
| Hayat Finans | Published (Dereci, Tabakoglu, Hayat) | Chair formerly headed BDDK participation supervision |
| Albaraka, Turkiye Finans, Dunya | Published | Standard annual compliance statements |
Committee turnover, when it happens, is itself disclosed through general assemblies: Dunya Katilim's April 2026 assembly seated Prof. Dr. Mehmet Islamoglu on a three-year term, replacing a departing member, and the appointment terms were public. Fixed terms and assembly-level appointments matter because they place the scholars' tenure in corporate governance rather than management's gift, one of the quieter strengths of the post-2019 system compared with the informal house-scholar arrangements of earlier decades.
The icazet question
An icazet is a written compliance certificate for a specific product. Every committee approves products internally; TOM Bank alone publishes the certificate itself, on the product page, for its participation account. This matters for the same reason printed ratio grids matter: it converts trust into verification. A saver at TOM can read the document their deposit's compliance rests on; a saver elsewhere relies on the committee's existence and reputation. We would like to see per-product icazet become sector standard, exactly as we argue printed rate tables should in our transparency audit.
What to check as a customer
- The roster: every bank should name its committee; both pre-launch banks (Adil Katilim, Iktisat Katilim) had not at our review, which is the first thing to verify at their launches.
- Activity evidence: meeting counts, decision counts, annual opinions. Emlak and TOM currently publish the most.
- Product-level artifacts: TOM's icazet today; watch for others following.
- Escalation rights: Vakif's TKBB path is the only written one; everywhere else, your recourse is the bank's own process.
- And weigh it in the choice: our Halal Money Index scores Shariah integrity and transparency explicitly, bank by bank, category by category.
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The honest summary: Turkey's oversight stack is institutionally serious, a binding regulation, senior scholars, sector standards, and its weakness is publication, not substance. Committees meet and decide constantly; savers see almost none of it. Until minutes and certificates become normal, bank with the institutions that show their work, and read our kar payi explainer for what the committees are actually protecting.
