Norway’s Wealth Fund and Turkey’s Market Manipulation Crisis 2026: What Turkish Law Offers Foreign Institutional Investors — Prospectus and Disclosure Liability (Capital Markets Law Arts. 10 and 32), the Six-Month Limitation Period, Tort Claims and the Criminal Case

Turkish version (Türkçe sürüm): Norveç Varlık Fonu “Fail Değil Mağduruz” Dedi: Yatırımcıların Hukuki Yolları

On 22 October 2026, Norway’s sovereign wealth fund, managed by Norges Bank Investment Management (NBIM), said it was among the investors hurt by Turkey’s investment fund crisis and that it was reviewing its Turkish shareholdings and the external managers who run them. At 30 June 2026 the fund held about NOK 20.4 billion (roughly USD 2.2 billion) of Turkish equities, of which about NOK 2 billion (roughly USD 208 million) sat in ten companies later drawn into the market-manipulation investigation. That figure is an exposure, not a confirmed loss, and we have found no public apology by the fund. This analysis sets out what Turkish law actually offers an institutional shareholder in NBIM’s position: liability for false or misleading prospectuses and public disclosures under Articles 10 and 32 of Capital Markets Law No. 6362, with a limitation period of only six months; tort claims against those who manipulated prices under Articles 49, 61 and 72 of the Turkish Code of Obligations; and the investor’s place in the criminal proceedings. It reflects public information as at 25 October 2026.

What NBIM said on 22 October 2026, and what it did not say

NBIM’s deputy chief executive, Trond Grande, spoke to journalists by telephone on Thursday, 22 October 2026, the day the fund published its third-quarter results. According to Bloomberg’s report of the call, he described the fund as more of a victim than a perpetrator in Turkey, explained that the fund reviews its investments when problems come to light, and confirmed that its Turkish holdings and the outside firms managing them were under review. He did not describe the outcome of that review, did not put a figure on the fund’s losses and did not announce any legal action.

Several numbers are now circulating, in Turkey and abroad, and they measure different things. In Turkey the story has also circulated as “Norway’s fund lost USD 200 million in Turkey and apologised to the Norwegian people”. Both halves of that sentence go further than the public record. The USD 208 million figure is the value of the fund’s positions in ten investigated companies on 30 June 2026, before the September collapse; it is a measure of exposure, not of a realised loss. And we have found no statement in which NBIM apologised to anyone over its Turkish investments; the public message was the opposite, namely that the fund regards itself as a party that suffered harm.

Two further details from the reporting matter legally. First, Bloomberg reported that in July 2026 the fund took part in an initial public offering arranged by a brokerage that has since become part of the investigation. Participation in a public offering brings the prospectus liability rules of Turkish capital markets law into play, which do not apply to ordinary secondary-market purchases in the same way. Second, part of the fund’s Turkish exposure was run by external managers rather than directly from Oslo, and before the crisis the fund had already cut ties with one Turkish firm after the Turkish regulator fined one of that firm’s senior managers for improper trading. Both points shape which legal routes are open, and against whom.

Turkey’s fund and market-manipulation crisis in brief

In mid-September 2026 several Turkish investment funds failed to meet redemption requests, and selling pressure spread across Borsa Istanbul. On 17 September 2026 the Capital Markets Board of Türkiye (Sermaye Piyasası Kurulu, “SPK”, also known in English as the CMB) closed to trading and ordered the liquidation of 131 investment funds run by seven portfolio management companies, holding the savings of more than 455,000 investors. Prosecutors in Istanbul are investigating allegations that funds were used to buy shares in little-known listed companies in order to push their prices up. By late October Turkish media reported that around one hundred suspects had been jailed pending trial, and the BIST 100 index had fallen by more than 20% from its level before the rout.

Alongside the criminal investigation, SPK has used its weekly bulletins to announce criminal complaints and two-year trading bans against dozens of individuals in connection with specific listed shares, and has stopped the activities of several brokerages. Those bulletins are public documents; for an investor building a damages claim they are the first map of who is alleged to have done what, in which shares and over which period.

On 22 October 2026, the same day as NBIM’s comments, the Turkish Grand National Assembly approved the Law on Certain Investment Funds Ordered into Liquidation (Tasfiyesine Karar Verilen Bazı Yatırım Fonları Hakkında Kanun). As at 25 October 2026 it had not yet been published in the Official Gazette, and it enters into force on publication. On the basis of the text as reported, the law:

• applies only to the funds SPK ordered into liquidation on 17 September 2026 whose liquidation was not complete when the law is published, and expressly creates no general regime for other funds;
• sets out interim payments to fund unit holders of up to TL 1 million per investor per fund, calculated on an inflation-adjusted net investment basis;
• bars any payment to persons whom SPK finds to have committed market-disrupting acts, insider dealing or market manipulation (Capital Markets Law Arts. 104, 106 and 107) together with the funds, or to have acted with them;
• makes the portfolio management company primarily liable for fund losses and, where it cannot pay, makes the individuals and entities identified by SPK personally liable, with collection by the Savings Deposit Insurance Fund (TMSF) under the public-receivables collection procedure;
• allows persons who profited from shares that SPK finds were artificially inflated to return the excess gain voluntarily to a general share return account announced by SPK.

For our purposes the important point is what the law does not do: it is a liquidation and repayment statute for fund unit holders. It does not create a compensation scheme for shareholders of listed companies whose share prices were manipulated, and it does not displace the ordinary remedies of the Capital Markets Law and the Code of Obligations.

Shareholder, not fund unit holder: why NBIM’s position is different

Most of the Turkish commentary on the crisis is written for retail savers who held units in one of the 131 liquidated funds. Their position is governed by SPK’s liquidation decisions and by the new law. An institution like Norway’s fund is in a different place. Its exposure was to shares of listed Turkish companies bought on Borsa Istanbul or in public offerings, held through custodians and, in part, through external managers. When those share prices collapsed after the manipulation came to light, the loss arose in the shareholder’s own portfolio, not inside a liquidated fund.

That has three consequences. The fund liquidation payments do not reach it. The payment ban in the new law, which excludes persons found to have acted together with the funds, does not concern it. And its remedies are the general ones available to any investor who bought or held securities at prices distorted by manipulation or by false information: claims against the issuer and the persons responsible for its public documents, claims in tort against the manipulators, and participation in the criminal case. The same is true of other foreign pension funds, sovereign funds and asset managers with Turkish equity books.

NBIM’s own test for going to court, read against Turkish law

NBIM publishes a policy on safeguarding legal interests, issued in 2008 and last updated on 12 June 2024. It records that Norges Bank is the legal owner of the assets the fund manages and that NBIM is obliged to preserve and pursue the bank’s legal interests, including by litigation where necessary. For securities litigation the policy says that a more active and direct approach should be considered only where six conditions are met: there were actions by the company, its management or its advisers that clearly appear to give rise to liability for damages; those actions caused losses to shareholders or bondholders; the bank’s losses are considerable; the case has a strong legal basis; there is sufficient material and evidence; and the defendants are believed to be able to pay. The policy also calls for an assessment of reputational impact before NBIM acts as a plaintiff.

The fund has acted on this policy before. In June 2016 it filed a claim against Volkswagen in the Braunschweig District Court in Germany as part of a joint action by institutional investors over the emissions scandal, and in December 2023 it was reported to be preparing, with the Swedish pension fund AP7, to lead a United States securities class action over the collapse of Silicon Valley Bank, its first such role. In announcing the latter, its chief executive described taking legal action both as a way to maximise recoveries and as a signal that such market behaviour is unacceptable.

Read against Turkish law, the six criteria translate into concrete questions:

Five legal routes under Turkish law

An institutional investor that lost money in shares affected by the 2026 manipulation cases has five possible routes in Turkey. They are not alternatives; in practice several are used together, and the choice between them is driven by the facts of each issuer, by the identity and solvency of the defendants and, above all, by time limits.

Prospectus and disclosure liability: Articles 10 and 32

Turkish capital markets law contains two investor-protection rules that are easy to overlook and powerful when they apply. Article 10 of Capital Markets Law No. 6362 deals with the prospectus. The issuer is liable for losses arising from false, misleading or incomplete information in the prospectus. If the loss cannot be recovered from the issuer, or it is clear that it cannot be, the offerors, the lead intermediary that arranged the issue, any guarantor and the issuer’s board members are liable to the extent that the loss can be attributed to them according to their fault and the circumstances. Under Article 10(2), independent audit, rating and valuation firms and others who prepared reports included in the prospectus are liable for false, misleading or incomplete information in their reports.

Article 32 then extends the regime to public disclosure documents in general and sets the rules that matter most in litigation. The persons named in Article 10, and those who sign the prospectus, the information form in a tender offer, special-event disclosures, merger and demerger announcements, the listing announcement, financial reports and other documents SPK requires for public disclosure, as well as the legal entities on whose behalf they sign, are jointly and severally liable for losses caused by false, misleading or incomplete information in those documents (Art. 32(1)). Report preparers such as auditors and valuers are also liable (Art. 32(2)).

Three further paragraphs give the regime its shape:

• Defence of the individual defendant (Art. 32(3)). A person is not liable if he proves that he did not know the information was false, misleading or incomplete and that his lack of knowledge was not due to his intent or gross negligence. The burden is on the defendant.
• Presumption of causation (Art. 32(4)). Where securities were bought in an IPO or on the exchange during the validity of a defective prospectus, or immediately after another defective disclosure was published, and were sold on the exchange immediately after the true information came out, causation between the document and the investor’s loss is deemed established.
• Grounds for rejection (Art. 32(5)). The claim is rejected if the purchase or sale was not based on the disclosure document, if the investor knew the information was wrong, if a correction was published before the investment decision, or if the investor would have suffered the loss even had the information been correct.

Finally, under Article 32(7), any agreement, clause or statement that limits or excludes this liability is invalid. Disclaimers in a prospectus do not protect the issuer or its advisers. A full commentary on both articles, the defences and the parallel Commercial Code routes is in Prospectus and Disclosure Liability in Turkey: Capital Markets Law Articles 10 and 32.

Why does this matter in the 2026 cases? Market manipulation under Article 107(1) is committed by trading, while Article 107(2) covers manipulation by spreading false or misleading information, rumours, news, comments or reports. Where a manipulation scheme involved inflated financial statements, unjustified special-event announcements about contracts, capacity or orders, or a prospectus that did not tell the truth, the disclosure route opens a claim against solvent parties, including the issuer itself and its auditors, with a statutory presumption of causation. That is precisely the type of “action on the part of the company, its management or its advisers” that NBIM’s policy treats as the trigger for direct litigation.

The six-month clock under Article 32(6)

The most important sentence in this analysis is Article 32(6) of the Capital Markets Law: a damages claim arising from public disclosure documents is time-barred six months after the date on which the loss described in Article 32(4) occurred. Six months is short by any international standard, and it is far shorter than the general two-year tort limitation period that many foreign lawyers would expect to apply.

The trigger is tied to the loss in Article 32(4), which describes securities sold on the exchange immediately after the true information came out. For many holders in the 2026 cases that points to sales in the second half of September and in October 2026, when the investigation became public and prices collapsed. Purely as an illustration: a loss that occurred on 20 September 2026 would become time-barred on 20 March 2027. For a holder that has not sold, the starting point is a matter of legal analysis, and a cautious claimant plans on the basis of the earliest date a court could adopt.

Two procedural rules affect the calculation. If the claim is classified as a commercial case (Turkish Commercial Code Art. 4) and is for a sum of money, an application to a mediator before filing is a condition of the action (Turkish Commercial Code Art. 5/A), and limitation is suspended from the application to the mediation office until the final report (Law No. 6325 on Mediation in Civil Disputes, Art. 18/A(15)). And under Article 109(4) of the Code of Civil Procedure, added by Law No. 7589 of 16 July 2026, a claimant who sues for part of a claim may increase the amount once, until the end of the evidence stage, and limitation is deemed interrupted from the filing date for the increased part as well. That makes it possible to stop the clock with a partial claim while the full loss is still being calculated.

Tort claims against those who manipulated prices

Where the loss was caused by manipulative trading rather than by a defective disclosure document, the claim lies in tort. Article 49 of the Turkish Code of Obligations requires anyone who causes loss to another by a culpable and unlawful act to compensate it. Market manipulation is a criminal offence under Article 107 of the Capital Markets Law, which makes the unlawfulness of the conduct straightforward to establish once the facts are proven.

Article 107(1) punishes those who buy or sell, place, cancel or change orders or carry out account movements in order to create a false or misleading impression about the prices, price changes, supply or demand of capital market instruments, with three to five years’ imprisonment and a judicial fine of 5,000 to 10,000 days; the fine may not be less than the benefit obtained. Article 107(2) punishes those who give false, wrong or misleading information, start rumours, publish news, make comments or prepare reports, or spread them, in order to influence prices, values or investors’ decisions, and thereby obtain a benefit, with three to five years’ imprisonment and a judicial fine of up to 5,000 days. Draft amendments reported in November 2025 would raise these penalties; the official consolidated text of the law still shows the figures above. The offence, SPK’s trading bans and the procedure from SPK finding to trial are explained in Market Manipulation under Turkish Law: Capital Markets Law Article 107 and SPK Enforcement.

Three features of tort law matter for an institutional claimant:

• Burden and quantum (Art. 50). The claimant must prove its loss and the defendant’s fault. If the exact amount cannot be proven, the judge determines it equitably, having regard to the ordinary course of events and the measures the claimant took.
• Joint and several liability (Art. 61). Where several persons together cause a loss, or are liable for the same loss on different grounds, they are jointly and severally liable. An investor may claim the whole loss from any of them, which is decisive when only some defendants have assets.
• Limitation (Art. 72). Two years from the date the claimant learned of the loss and of the person liable, and in any case ten years from the act; but if the act is a crime for which criminal law provides a longer limitation period, that period applies.

The weak point of a pure manipulation claim is causation and quantum for a secondary-market buyer: the investor must show how much of its loss is attributable to the artificial price rather than to the general market fall. The shares themselves are not the proof; price and volume data around the manipulation period, the findings in SPK’s criminal complaints and the expert reports in the criminal file usually are. This is why the criminal case matters even to an investor who will never ask for a conviction.

The criminal proceedings and the investor’s place in them

Capital markets offences are prosecuted in a particular way. Under Article 115(1) of the Capital Markets Law, an investigation into any offence defined in that law depends on a written application by SPK to the public prosecutor; the application is a procedural condition. When an indictment is accepted, SPK is notified and automatically becomes a participating party (Art. 115(2)), and SPK may object if the prosecutor decides not to prosecute (Art. 115(4)). This is why every 2026 manipulation case starts with an SPK decision to file a criminal complaint, published in its bulletin.

The investor’s own position is governed by the Criminal Procedure Code. In the investigation stage, a victim or complainant may ask for evidence to be collected and, without prejudicing the confidentiality and purpose of the investigation, ask the prosecutor for copies of documents (Art. 234). Once a public prosecution has been brought, the victim and natural or legal persons harmed by the offence may join the case as participating parties at any stage of the first-instance trial until judgment, by declaring that they are complainants (Art. 237(1)); participation cannot be requested for the first time on appeal (Art. 237(2)). Whether an investor who traded on the exchange counts as a person harmed by a market-manipulation offence is decided by the court on the facts; it is not automatic, and SPK’s own participation does not replace the investor’s. A step-by-step guide is in Joining a Criminal Case in Turkey as a Foreign Investor.

The criminal case does not award the investor its damages; those are claimed in the civil courts. But it gives the investor three things that are hard to obtain elsewhere in Turkish procedure: access to the evidence gathered by prosecutors and SPK experts, the ability to influence how that evidence is collected and presented, and the right to appeal as a party. For a claimant that must prove causation and quantum, that is often decisive.

Practical questions for a foreign claimant

Security for costs

Under Article 48 of Law No. 5718 on Private International and Procedural Law, foreign individuals and legal entities that bring an action in a Turkish court must provide security, set by the court, for costs and for the other side’s loss, unless the court exempts them on the basis of reciprocity. Both Norway and Türkiye are parties to the Hague Convention of 1 March 1954 on civil procedure (in force for Norway since 1958 and for Türkiye since 1973), whose Article 17 bars requiring security from nationals of a contracting state domiciled in one of those states solely because they are foreigners. How a Turkish court applies these rules to a particular claimant, including a central bank acting as the legal owner of a sovereign fund, should be addressed in the statement of claim rather than left to chance.

Power of attorney and documents

Turkish proceedings are conducted through a Turkish lawyer holding a power of attorney. Both countries are parties to the Hague Apostille Convention of 1961 (Norway since 1983, Türkiye since 1985), so a power of attorney executed before a notary in Norway can be apostilled instead of legalised. Proceedings are in Turkish, and foreign-language documents are filed with sworn Turkish translations. Corporate authority documents, custody statements, trade confirmations and IPO allocation records should be assembled early. The rules on who may act, the express authorities a power of attorney must contain and how fees are agreed are explained in Representing Foreign Institutional Investors in Turkish Capital Markets Disputes.

Court fees and the partial claim

In a money claim the judgment fee is proportional: 68.31 per thousand of the amount awarded, a quarter of which is paid in advance on filing and the balance within one month of service of the judgment (Fees Law No. 492, Art. 28(a) and Tariff 1). On a claim in the hundreds of millions of lira the advance fee alone is substantial. The partial claim under Article 109 of the Code of Civil Procedure, now combined with the right to increase it once under Article 109(4), allows a claimant to file for part of its loss, pay the advance fee on that part, interrupt limitation and increase the claim later. The former “claim for an undetermined amount” under Article 107 was repealed by Law No. 7589 in July 2026, so the partial claim is now the main tool for this purpose.

No class action, but joint claims

Turkey has no opt-out class action of the kind NBIM has used in the United States. Article 113 of the Code of Civil Procedure lets associations and other legal entities sue in their own name to protect the interests of their members, but only to establish rights, remove an unlawful state of affairs or prevent future violations, not to recover damages for them. Institutional investors with similar claims can, however, sue together as optional co-plaintiffs where their claims rest on the same or similar facts and legal grounds (Art. 57(1)(c)); each claim remains independent (Art. 58). Coordinated claims by several foreign funds against the same issuer or the same group of defendants are therefore possible and efficient.

Evidence without discovery

There is no pre-trial discovery in the common-law sense. Two tools fill part of the gap: an application for preservation of evidence before or during proceedings, such as an expert examination, where there is a legal interest and the evidence may otherwise be lost or become much harder to use (Code of Civil Procedure Art. 400), and orders requiring the other party to produce specific documents, with consequences if it fails to do so (Art. 220). Combined with the criminal file, these are usually enough to build a damages case.

Who can actually pay? Assets, seizures and trustees

NBIM’s sixth criterion, that the defendants should be able to pay, is where Turkish cases are often won or lost. Individuals accused of manipulation may hold little in their own names; brokerages whose activities SPK has stopped may have few free assets; and several issuers have collapsed. A realistic recovery plan therefore looks at several layers at once:

• Issuers that remain solvent. Under Article 10 the issuer is the primary defendant for prospectus losses, and under Article 32 it is jointly and severally liable with the signatories of its disclosure documents.
• Audit, rating and valuation firms. They answer for their own reports under Articles 10(2) and 32(2), and they are usually solvent and insured.
• Board members. They are secondary defendants for prospectus losses under Article 10(1) and, as signatories, are liable for disclosure documents under Article 32(1).
• Seized assets of suspects. In the criminal investigation, immovable property, rights and receivables can be seized (Criminal Procedure Code Art. 128), and a trustee may be appointed to manage them (Art. 128(10)). Under Article 55(1) of the Turkish Criminal Code, proceeds of an offence are confiscated only where they cannot be returned to the victim, which gives participating victims a priority argument over the State.
• Companies placed under a trustee. Where there is strong suspicion that an offence is being committed within a company’s activities, the court may appoint a trustee to run it (Criminal Procedure Code Art. 133); in the 2026 cases TMSF has been appointed in this role in at least one listed holding company. Claims against such companies continue, but are directed at entities whose management has changed.

An institutional investor rarely needs to win against every defendant. Joint and several liability under Article 61 of the Code of Obligations and Article 32(1) of the Capital Markets Law means that the claim can be concentrated on those who can pay, leaving them to seek contribution from the others.

External managers and intermediaries

NBIM has said that its review covers the outside firms that manage its Turkish investments. Claims between a global investor and its external manager are normally governed by the investment management agreement, including its choice of law and forum, and often will not be decided under Turkish law at all. Turkish law becomes relevant when the question is what a Turkish-licensed manager or broker was required to do under Turkish capital markets rules, when the manager’s own Turkish counterparties or brokers acted unlawfully, or when assets held through a Turkish intermediary are affected by an SPK measure.

Two practical points follow. First, the review of an external manager and the claims against issuers and manipulators should run in parallel, not in sequence, because the six-month period under Article 32(6) does not wait for the internal review. Second, the trading records held by the external manager are the core evidence for every route described above; they should be preserved and obtained in a usable form before any dispute with the manager makes cooperation harder.

A first-90-days checklist for institutional holders

1. Preserve all trading records for Turkish equities from January 2025 onwards: orders, executions, custody statements, IPO applications and allocations, and internal research notes.
2. Map each position against SPK’s weekly bulletins (criminal complaints and trading bans) and against public reports of the investigation, issuer by issuer.
3. Identify every public disclosure document relevant to each position: the prospectus, KAP special-event disclosures and financial reports, with dates and signatories.
4. Calculate, for each issuer, the earliest date on which a court could say the loss under Article 32(4) occurred, and diarise six months from that date.
5. Estimate the loss attributable to the artificial price, not merely the total fall in value, with the help of a market expert.
6. Screen defendants for solvency: issuers, auditors and valuers, board members, intermediaries, and suspects whose assets have been seized.
7. Decide whether to inform SPK and the prosecutor and to seek participation in any criminal case once an indictment is accepted.
8. Prepare apostilled corporate authority documents and a power of attorney for Turkish counsel.
9. Speak to other institutional holders of the same issuers about joint claims under Article 57 of the Code of Civil Procedure.
10. Decide on the size of the first, partial claim and the mediation step, so that limitation is interrupted in time and fees remain proportionate.

Common mistakes

• Assuming a two-year limitation period. For claims based on prospectuses and other disclosure documents, it is six months from the loss.
• Waiting for the criminal judgment. Criminal cases of this size take years; civil limitation periods continue to run in the meantime unless they are interrupted or suspended.
• Treating the fund liquidation law as a compensation scheme. It deals with unit holders of the liquidated funds, not with shareholders of manipulated companies.
• Suing only the obvious individuals. Issuers, auditors, valuers and board members may be liable under Articles 10 and 32, and are more likely to be able to pay.
• Claiming the whole market fall. A court will compensate the loss caused by the false information or the manipulation, not the general decline of the Turkish market.
• Leaving the paperwork to the end. Apostilles, translations and corporate authorities take weeks; with a six-month limit, those weeks matter.

Frequently asked questions

Did Norway’s wealth fund lose USD 200 million in Turkey?

Not as a confirmed figure. About NOK 2 billion (roughly USD 208 million) was the value at 30 June 2026 of the fund’s stakes in ten Turkish companies later drawn into the market-manipulation investigation. NBIM has not published a loss figure. A press calculation by Türkiye Today estimated that the fund’s whole Turkish portfolio fell by more than USD 300 million between 30 June and 22 October 2026, but that is not NBIM data.

Did NBIM apologise to the Norwegian public over its Turkish losses?

We have found no such statement. On 22 October 2026 the fund’s deputy chief executive said the fund saw itself as more a victim than a perpetrator and was reviewing its Turkish holdings and external managers.

Can a foreign institutional investor recover market-manipulation losses in a Turkish court?

Yes, on the same footing as a Turkish investor. The main routes are liability for false, misleading or incomplete prospectuses and disclosure documents under Articles 10 and 32 of Capital Markets Law No. 6362, tort claims against the manipulators under Articles 49, 61 and 72 of the Turkish Code of Obligations, and participation in the criminal case under Article 237 of the Criminal Procedure Code.

How long does an investor have to sue under Turkish law?

Claims arising from public disclosure documents, including prospectuses, are time-barred six months after the loss described in Article 32(4) of the Capital Markets Law occurred (Art. 32(6)). General tort claims are time-barred two years after the claimant learned of the loss and the person liable, and in any case ten years after the act, or later where the act is a crime with a longer limitation period (Turkish Code of Obligations Art. 72).

Does the October 2026 fund liquidation law help shareholders of listed companies?

No. The law approved by parliament on 22 October 2026 covers the investment funds SPK ordered into liquidation on 17 September 2026 and their unit holders. Shareholders of listed companies whose prices were manipulated must rely on the Capital Markets Law and the Code of Obligations.

Can institutional investors bring a class action in Turkey?

There is no opt-out class action for damages. Associations can sue only for declaratory or preventive relief (Code of Civil Procedure Art. 113). Several investors can, however, sue together as co-plaintiffs where their claims rest on the same or similar facts and legal grounds (Art. 57).

Must a foreign claimant provide security for costs?

Foreign claimants must provide security set by the court unless exempted on the basis of reciprocity (Law No. 5718 Art. 48). Norway and Türkiye are both parties to the 1954 Hague Convention on civil procedure, whose Article 17 restricts security requirements imposed solely on grounds of foreign nationality.

Can an investor take part in the criminal case against alleged manipulators?

The victim and persons harmed by the offence may join a public prosecution as participating parties until judgment at first instance (Criminal Procedure Code Art. 237). The court decides whether an investor qualifies. SPK becomes a participating party automatically when the indictment is accepted (Capital Markets Law Art. 115(2)), but that does not replace the investor’s own participation.

What does it cost to file a damages claim in Turkey?

The judgment fee in a money claim is 68.31 per thousand of the amount, a quarter of which is paid on filing (Fees Law No. 492, Art. 28(a) and Tariff 1). A partial claim under Article 109 of the Code of Civil Procedure, which can be increased once until the end of the evidence stage, keeps the advance fee proportionate while interrupting limitation.

Related guides

• Turkey’s 2026 Fund and Market Manipulation Crisis: Legal Guide for Foreign Institutional Investors — the entry point to this series: which route fits which exposure, liable parties and deadlines
• Turkish Bond Defaults: Bondholders’ Boards and Enforcement
• Continuous Disclosure in Turkey: Inside Information and Delayed Disclosure
• How a Securities Lawsuit Proceeds in Turkey
• Limitation Periods for Investor Claims in Turkey
• Concealed Profit Transfers and Controlling Shareholder Liability
• Claims Against Brokers, Custodians and Portfolio Managers in Turkey
• When a Turkish Issuer or Broker Becomes Insolvent
• Obtaining and Preserving Evidence in Turkey for Securities Claims — preservation, document production and the criminal file
• Shareholder Rights in Turkish Listed Companies after the 2026 Crisis — general meetings, release, annulment and exit rights
• Insider Dealing in Turkey: Capital Markets Law Article 106 — trading on non-public information
• Calculating Damages in Turkish Securities Claims — loss, interest and currency
• Suing in Turkey or Abroad: Jurisdiction and Enforcement — forum choice and enforcement of foreign judgments and awards
• Suing Turkey’s Capital Markets Board (SPK) — challenging SPK decisions and supervisory failure claims
• Suing Directors and Auditors of Turkish Listed Companies — board members, managers and audit firms
• Can Foreign Investors Bring a Class Action in Turkey? — joint claims, consolidation, association actions and assignment
• Freezing Assets in Turkey for Investor Claims — precautionary attachment, interim injunctions and criminal seizure
• Legal Guide for Foreign Investors in Turkey (Türkiye) 2026 — the full English-language guide
• Joining a Criminal Case in Turkey as a Foreign Investor — complaints, file access, objections and participating-party status
• Market Manipulation under Turkish Law: Capital Markets Law Article 107 and SPK Enforcement — the offence, SPK trading bans and the path to a criminal trial
• Prospectus and Disclosure Liability in Turkey: Capital Markets Law Articles 10 and 32 — who is liable, presumed causation and the six-month limitation period in detail
• Representing Foreign Institutional Investors in Turkish Capital Markets Disputes — who may act before Turkish courts, powers of attorney, fees and confidentiality
• Turkey’s 2026 Fund Liquidation: Legal Guide for Foreign Investors and Companies — for holders of units in the 131 liquidated funds
• Can Foreign Investors Buy Shares on Borsa Istanbul? — accounts, custody and disclosure thresholds
• Investment Arbitration and ICSID — treaty remedies against measures of the State
• Piyasa Dolandırıcılığı (Manipülasyon) Suçu — the market manipulation offence, Art. 107 (in Turkish)
• Sermaye Piyasası Suçları ve Kurul Başvurusu — SPK’s written application as a condition of prosecution (in Turkish)
• Sermaye Piyasası Suçlarında Katılan ve Mağdur Hakları — victims and participating parties in capital markets cases (in Turkish)
• Halka Arz Yatırımcı Rehberi — IPO investors’ guide (in Turkish)
• SPK Bülteni Kararları Rehberi — reading SPK’s weekly bulletins (in Turkish)
• Fon Tasfiyesi Hukuk Rehberi — the fund liquidation hub (in Turkish)
• Fon Krizi Gündemi — day-by-day tracker of the fund crisis (in Turkish)
• SPK Hukuk Rehberi — Turkish capital markets law hub (in Turkish)