Eriş Bağımsız Denetim ve YMM A.Ş. · Compliance Guide
Responsibilities of the Accounting Department
What a finance function in Türkiye has to file, keep and be able to prove — set out as the recurring calendar the department actually works to. This revision reflects the rules in force in the 2026 accounting period. Several duties that appeared on the earlier version of this page no longer exist, and one that was abolished has since come back; both are set out below rather than quietly edited away.
01 · WHAT CHANGED
Five duties on the old version of this page are gone
If your internal checklist still follows the previous edition, these are the lines to strike out first. Each is a genuine repeal or merger, not a change of date.
No longer required
Struck out
- Form Ba and Form Bs notifications. Abolished outright from the September 2024 period onward.
- A separate monthly SGK premium and service document. It is now inside a single combined return.
- A separate withholding tax return. Same merger.
- Notary approval of the journal and the general ledger — for anyone keeping electronic books, which now covers most companies of any size. Note that this does not extend to the inventory book, which stays on paper unless the optional electronic version is chosen.
- Paper invoices for taxpayers keeping books on a balance sheet basis.
In force instead
What replaced them
- Withholding and Premium Service Return (Muhtasar ve Prim Hizmet Beyannamesi), one filing by the 26th covering both tax withholding and social security.
- e-Ledger berat uploads on their own timetable, replacing the notary cycle for electronic books.
- e-Fatura and e-Arşiv Fatura, with thresholds low enough that most active businesses are inside the system.
- A fourth advance tax period, restored for periods beginning on or after 1 January 2025 after having been removed in 2022.
- Data protection registration and the foreign currency transaction restriction, neither of which existed when this page was first written.
Deadlines are given as the rule in the statute or communiqué. In practice the Revenue Administration extends particular deadlines by circular, often only days beforehand, and a deadline falling on a weekend or public holiday rolls to the next working day. Work to the statutory date and check the current circular before relying on an extension.
02 · BOOKS AND RECORDS
Which books, and who has to certify them
The Turkish Commercial Code requires opening and closing approvals for books kept on paper. Article 64 is explicit that these approvals are not sought where the books are kept electronically, which is the position most companies are now in.
| Book | Opening approval | Closing approval | Note |
|---|---|---|---|
| Journal | By the end of the month preceding the first month of the accounting period, so by the end of December for a calendar year | End of the sixth month | Closing approval is due by the end of the sixth month of the following accounting period, so the end of June |
| General ledger | Same as the journal | None | No closing approval is prescribed |
| Inventory book | Same as the journal | None | Still a paper book with a notary opening approval even for companies on electronic books, unless the optional electronic inventory book is adopted. The earlier version of this page showed a June closing here; that deadline belongs to the journal |
| Board of directors resolution book | Same as the journal | End of the first month | Closing approval by the end of the first month of the following period, so the end of January |
| Share register | Before first use | None | May continue to be used in later periods without a fresh opening approval, provided enough pages remain |
| General assembly meeting and negotiation book | Before first use | None | Same continuation rule as the share register |
On incorporation, the trade registry does it. For joint stock and limited companies the opening approvals are made by the trade registry directorate at the time of registration, not by a notary.
Electronic books need no approval. Where the commercial books are kept electronically, neither notary nor trade registry approval is sought for the opening of those books or for the closing of the journal and the board resolution book. What replaces it is the berat upload described below.
But the electronic ledger is only two books. The application covers the journal and the general ledger. The inventory book is outside it and therefore still has to be kept on paper with a notary opening approval, unless the company adopts the electronic inventory book that a 2024 amendment to the Electronic Ledger Communiqué made available as an option. The board resolution book, share register and general assembly book are likewise unaffected.
A book with pages left can be renewed rather than reopened. Where a paper book has enough unused pages, it may be carried into the following period with a renewal approval taken by the end of the first month of that period, instead of a fresh opening approval in December.
e-Ledger berat uploads
Electronic books are created monthly but proved by uploading a berat to the Revenue Administration. A company chooses one of two rhythms at the start of the year and keeps to it. For corporate taxpayers:
| Option | Deadline | Worked example |
|---|---|---|
| Monthly | By the end of the 14th day of the fourth month following the month concerned | January books, uploaded by 14 May |
| Advance tax period | By the end of the 14th day of the month following the month in which that period’s advance tax return is due | April to June books, uploaded by 14 September |
The final quarter is tied to the annual corporate tax return rather than to an advance tax return, which puts its berat in May of the following year; restoring the fourth advance tax period did not change this. Income tax payers who are individuals follow the same structure on the 10th rather than the 14th. Late upload exposes the company to an irregularity penalty, and for the period concerned the ledger is not proved.
03 · TAX CALENDAR
The month has three fixed points
Most of the recurring work lands on three days. Everything else in the tax calendar is quarterly or annual.
Each of the three marked days is both the filing date and the payment date for the taxes shown. The 14th applies only in the months in which a berat upload falls due under the option the company has chosen.
| Return | Covers | Filing deadline | Payment deadline |
|---|---|---|---|
| Withholding and Premium Service Return | Income tax withheld at source and the social security premium and service data for the same month, in one filing | 26th of the following month | 26th for the tax; premiums by the end of the following month |
| Value added tax | Monthly VAT | 28th of the following month | 28th of the following month |
| Stamp tax | Stamp tax on documents, for taxpayers filing continuously | 26th of the following month | 26th of the following month |
| Advance corporate tax | Four periods a year, each measured cumulatively from the start of the year | 17th of the second month following the end of the period | Same day as filing |
| Corporate income tax | The accounting period as a whole | From the 1st to the last day of the fourth month following the close of the period, so 1 to 30 April for a calendar year | Same day as the filing deadline |
| Real estate tax | Property owned at 1 January | Only on acquisition or on a change affecting the assessment | First instalment March to May, second instalment in November |
The fourth advance tax period was removed from 2022 and restored for taxation periods beginning on or after 1 January 2025. The change works by deleting the words that had limited advance tax to the first nine months of the year, so the fourth period covers the full twelve months on a cumulative basis and what was paid in the earlier periods is set against it.
In practical terms the fourth period return falls due on 17 February of the following year. A calendar built on the three-period pattern will miss it.
Several of the deadlines above come from a circular rather than from the statute behind them. In 2019 the Revenue Administration aligned the filing deadline of a number of returns with their payment deadline, open-endedly, until a fresh determination is made. That is why the withholding and stamp tax returns are due on the 26th rather than the statutory 23rd, and why the corporate tax return runs to the end of April rather than to the 25th. The VAT date moved again afterwards, to the 28th, by a later circular.
The practical point is that these are the operative dates and have been for years, but they rest on an instrument the administration can replace. A deadline that looks settled is worth re-checking at the start of each year rather than carried forward from the last one.
04 · PAYROLL AND SOCIAL SECURITY
Deadlines that run before the work starts
The distinctive feature of Turkish social security compliance is that the main notification is due before the employee begins, not after. Most penalties in this area come from treating it as a post-hire formality.
| Obligation | Deadline | Note |
|---|---|---|
| Workplace registration | On the date the first insured employee starts work, at the latest | Required once per workplace |
| Employment entry notification | At least 1 day before | Construction, fishing and agricultural work may notify on the day work starts. Foreign nationals have their own periods running from the work permit |
| Employment contract | On the first day of employment | A written contract is required for fixed-term work and for any term of one year or more |
| Employment exit notification | Within 10 days | Counted from the date the contract ends |
| Work accident notification | Within 3 working days | Counted from the accident. Notification to the police, where required, is immediate |
| Withholding and Premium Service Return | 26th of the following month | This single return carries the social security premium and service data. There is no longer a separate monthly premium document |
| Premium payment | By the end of the following month | Later than the return itself |
| Missing day notification | With the return for the month concerned | Filed as part of the same return where the employee has days not worked |
| Payroll and payslip | Payslip given whenever wages are paid | May be given electronically where the employee can be shown to have received it |
| Annual leave record | Kept continuously | Leave taken is recorded and signed; the record must be producible on inspection |
The threshold at which wages, premiums, bonuses and similar entitlements must be paid through a bank was reduced from five employees to three, counted across Türkiye rather than per workplace, with effect from 1 July 2025. An employer with three employees who still pays in cash is in breach for each employee for each month.
05 · ELECTRONIC DOCUMENTS
The chain from invoice to archive
Electronic documents are not simply a different way of printing an invoice. They form a chain in which each link has its own deadline, and a gap at any point is visible to the administration without an inspection ever being opened.
Commercial books and the documents behind them are retained for ten years under the Turkish Commercial Code; the tax law retention period is five years, so the longer one governs in practice.
Who has to be inside the system
The thresholds have fallen steadily and are now low enough that the question for most operating companies is when, not whether.
| Application | Threshold | From |
|---|---|---|
| e-Fatura, general | Gross sales revenue of 3 million TL, measured for 2025 or a later accounting period | 1 July 2026 for the 2025 measurement |
| e-Fatura, risk-focused activities | Gross sales revenue of 500 thousand TL. Covers online sales, real estate and motor vehicle dealing and rental, and internet advertising | 1 July 2026 for the 2025 measurement |
| e-Fatura, no threshold at all | Accommodation businesses licensed by the Ministry of Culture and Tourism or the municipality, and certain other listed activities | From the start of the activity |
| e-Arşiv Fatura | Required for invoices that are not e-Fatura. For taxpayers keeping books on a balance sheet basis the paper invoice has ended | 1 January 2026 |
| Paper invoice, what is left of it | Taxpayers whose commercial income is determined on the simplified basis, and those keeping books on an operating account basis, may still issue paper invoices | Until 31 December 2026 |
| e-Defter | Follows the e-Fatura obligation for taxpayers on a balance sheet basis | From the start of the year following entry into e-Fatura |
Cancelling or objecting to an electronic invoice is a separate procedure with its own eight-day and mid-month deadlines, and the commercial law objection is not the same thing as the cancellation request in the portal. We set the two out side by side in our guide to cancellation and objection in e-invoicing, and the exemption and special base codes used when issuing are listed in e-Fatura exemption and special base codes.
06 · THE ROUTINE
Daily, weekly and monthly work
Deadlines are the visible part of the job. What makes them achievable is the routine underneath, which has changed less than the legislation has.
Daily
- Post every transaction to the accounting system: cash, bank, expenses, purchases, sales, payments and collections
- Issue invoices and delivery notes, and check that electronic documents have actually reached the recipient
- Download and match bank movements
- File source documents so that each entry can be traced back to one
- Take a backup, and confirm the backup can be restored
Weekly
- Give management the receivables and payables position
- Review invoices received but not yet posted
- Check that incoming e-invoices have been accepted or rejected within the period allowed
- Follow up documents missing from expense claims
Monthly
- Reconcile supplier and customer balances directly with the counterparty, now that the Ba and Bs cross-check no longer exists
- Accrue payroll, rent and similar charges
- Instruct the bank for wage payments
- Count stock and report differences
- File the month’s returns and payroll together
- Report to the Ministry of Industry and Technology where an investment incentive certificate is held
The Ba and Bs forms were, in practice, a free reconciliation: a mismatch with a counterparty surfaced through the administration. With the forms abolished, that check has gone and nothing replaced it. Balances now have to be agreed directly with the counterparty, and the discipline of doing so monthly matters more than it did, not less.
07 · DUTIES THE DEPARTMENT ALSO OWNS
Obligations that sit outside the tax calendar
These rarely appear on an accounting checklist because they are not returns. They are nonetheless enforced against the company, and the finance function is usually the only place where the information needed to comply exists.
Is the company subject to independent audit?
The test is arithmetical and is applied to the two preceding accounting periods. For companies not within the specially listed categories, the general thresholds are:
Thresholds set for accounting periods beginning on or after 1 January 2026. Banks, insurers, listed companies and other specially listed entities are audited on different criteria or without any threshold at all.
Exceeding the test in two consecutive periods brings the company within statutory audit from the following period. The practical consequence for the accounting department arrives earlier than the audit does: the financial statements must be prepared under the applicable reporting framework, and the supporting records have to be in a condition to be tested. Our independent audit practice page sets out what that involves.
Personal data registration
A data controller must register with the data controllers registry before beginning to process personal data. Registration is required where the annual number of employees is 50 or more, or the annual financial balance sheet total exceeds 100 million TL. A controller established abroad registers through a representative whatever its size. Payroll alone makes the finance function a processor of employee data, so the obligation is rarely academic.
Two points are commonly got wrong, in opposite directions:
- A number of professions are exempt, not caught. Lawyers in respect of their practice, notaries, mediators, customs brokers and certified public accountants and sworn financial advisors in respect of their own professional activity are outside the registration obligation regardless of size, as are political parties, associations, foundations and unions in respect of their member records, and controllers that process personal data only by non-automated means. This firm is itself in that category.
- Processing special category data no longer catches every controller. A controller whose main activity is the processing of special categories of personal data used to be inside the registry whatever its size. Since a Board decision effective 1 October 2025 such a controller is exempt if it has fewer than 10 annual employees and an annual financial balance sheet total below 10 million TL.
The foreign currency transaction restriction
Contracts between residents in Türkiye may not be denominated in or indexed to a foreign currency except in the cases the legislation permits, and the exceptions are narrower than they are usually assumed to be. The department signing off a payment is often the last point at which a non-compliant contract can be caught. We maintain a working guide at Is your transaction within the foreign currency restriction?
The archive
The older edition of this page treated the archive as a filing exercise. With books and invoices now electronic, it is closer to an IT control:
- Electronic ledgers, berats and archive invoices are retained in electronic form for the full period and must remain readable, which means migrating formats before the software that reads them is retired
- Retention is ten years under the Commercial Code and five under the tax law; plan to the longer period
- Backups are held in a second physical location, and restoration is tested rather than assumed
- Access to accounting systems is restricted by role, and leavers are removed on the day they leave
- Paper documents that remain, such as signed contracts, notarised books from earlier years and personnel files, still need fire and theft precautions and a disposal procedure for documents whose period has expired
08 · SOURCES
Where these rules come from
Each statement above traces to one of the following. Where a deadline is set by a circular rather than by statute, this is noted in the text.
Turkish Commercial Code No. 6102, article 64
Opening and closing approvals of commercial books, and the exemption for books kept electronically.
Tax Procedure Law General Communiqué No. 565
Official Gazette of 25 September 2024, No. 32673. Ends the Form Ba and Form Bs notification from the September 2024 period onward.
Tax Procedure Law Circular No. 115
Dated 29 March 2019, applying from 1 April 2019 until a fresh determination is made. Aligns the filing deadline of several returns with their payment deadline: this is the source of the 26th for the withholding and stamp tax returns and of the end of April for the corporate tax return.
Tax Procedure Law Circular No. 149
Dated 22 December 2022. Moves the VAT return filing and payment deadline to the 28th of the following month, from the period beginning December 2022.
Law No. 7566, article 2
Official Gazette of 19 December 2025, No. 33112. Amends repeated article 120 of the Income Tax Law by removing the words limiting advance tax to the first nine months, restoring the fourth advance tax period for taxation periods beginning on or after 1 January 2025.
Tax Procedure Law General Communiqué No. 509, and No. 589 amending it
Scope and thresholds for e-Fatura, e-Arşiv Fatura, e-İrsaliye and the other electronic documents. No. 589, Official Gazette of 31 December 2025, sets the 1 January 2026 date and leaves paper invoicing available to simplified-basis and operating-account taxpayers until 31 December 2026.
Electronic Ledger General Communiqué No. 1, as amended, including No. 6
Creation of electronic books and the berat upload deadlines. No. 6, of 31 December 2024, makes the inventory book available in electronic form as an option and removes associations, foundations and cooperatives from the scope.
Social Insurance and General Health Insurance Law No. 5510, and the Social Security Institution’s statement of employer obligations
Workplace registration, employment entry and exit notifications, work accident notification, the combined return and the premium payment deadline.
Regulation on the payment of wages, premiums, bonuses and similar entitlements through banks, as amended
Official Gazette of 4 June 2025. Reduces the threshold from five employees to three with effect from 1 July 2025.
Presidential Decree No. 11066 on companies subject to independent audit
Official Gazette of 17 March 2026, No. 33199. General thresholds of 500 million TL total assets, 1 billion TL annual net sales and 150 employees, for accounting periods beginning on or after 1 January 2026.
Law No. 6698 on the Protection of Personal Data, article 16, and the Regulation on the Data Controllers Registry
The registry and the criteria for compulsory registration, together with the Personal Data Protection Board decisions exempting particular professions and, from 1 October 2025, small controllers whose main activity is the processing of special categories of personal data.
This revision reflects the position in the 2026 accounting period. Thresholds expressed in Turkish lira are revalued and the administration extends individual deadlines by circular during the year, so confirm the current figure and the current circular before acting on any single line.
Disclaimer. This page is general information and is not legal advice or tax advice on any particular matter. It summarises obligations that apply differently depending on a company’s size, sector, accounting method and history, and it does not cover sector-specific regimes. Please take advice on your own circumstances before acting. Legislative texts referred to belong to their official sources.