Pursuant to Article 397 of the Turkish Commercial Code No. 6102, the Decision on the Amending the Criteria for Determining Companies Subject to Independent Audit (“Decision”) was published in the Official Gazette dated 17 March 2026 and entered into force.
With the amendment, the audit thresholds have been updated for companies, other than (i) those listed under Annex (I) and Annex (II) of the relevant Decision and (ii) companies deemed public companies under the applicable legislation. Accordingly, for fiscal periods starting on or after 1 January 2026, the following criteria shall be applied in determining whether companies are subject to independent audit:
- The minimum threshold for total assets has been increased from TRY 300 million to TRY 500 million.
- The annual net sales revenue threshold has been increased from TRY 600 million to TRY 1 billion.
- No changes have been made to the number of employees threshold, which remains at 150 employees.
In addition to above, companies established in Türkiye in accordance with the Natural Gas Market Law, in which more than half of the share capital is directly or indirectly owned by Public Economic Enterprises, have been included in Annex (I) of the Decision and shall be subject to mandatory independent audit without being subject to any thresholds or criteria.
Under the new regulation, companies exceeding at least two of the applicable thresholds for two consecutive financial periods shall be subject to mandatory independent audit. Accordingly, it is crucial for companies to assess their status in line with the updated thresholds and, where applicable, proceed with the appointment of an independent auditor.
English