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Significant amendments have been introduced to the Decision on the Determination of Companies Subject to Independent Audit by the Presidential Decision numbered 11066, published in the Official Gazette dated 17 March 2026 and numbered 33199.
With these amendments, certain criteria for being subject to independent audit have been redefined; in particular, the general threshold values have been significantly increased, and the scope has been updated with respect to certain groups of companies. The amendments entered into force to be applicable for financial periods starting on or after 1 January 2026.
The key amendments are summarized below:
General threshold values have been significantly increased.
Under the Decision, substantial increases have been made to the general thresholds used in determining whether companies are subject to independent audit.
In this context, the thresholds previously set at:
- TRY 300 million for total assets, and
- TRY 600 million for annual net sales revenue
have been increased to:
- TRY 500 million for total assets, and
- TRY 1 billion for annual net sales revenue.
The employee threshold has remained unchanged at 150.
Companies exceeding at least two of these thresholds for two consecutive financial periods will be subject to independent audit.
The scope has been expanded with respect to companies affiliated with state economic enterprises.
With the amendment to item 9 of Annex (I) to the Decision, the scope of companies subject to independent audit has been broadened.
Under the previous regulation, only state economic enterprises (“SEEs”) and their subsidiaries were subject to independent audit. With the amendment, the scope has been extended to include:
- in addition to SEEs and their subsidiaries,
- companies established in Türkiye under the Natural Gas Market Law, and
- companies in which SEEs directly or indirectly hold more than 50% of the share capital
which are now also subject to independent audit.
It should be noted that the threshold values applicable to companies deemed publicly held under the Capital Markets Law and companies listed in Annex (II) to the Decision remain unchanged. Annex (II) covers, inter alia, companies subject to the regulation and supervision of the Information and Communication Technologies Authority, SDIF subsidiaries and companies under SDIF administration, and companies in which at least 50% of the share capital is held by municipalities.
The full text of the Decision can be reached through this link. (Only available in Turkish)
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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