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20 October 2025

Amendments Regarding The Keeping Of Commercial Books In Electronic Form

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The Amendment Communiqué on the Communiqué ("Communiqué") on the Keeping of Non-Accounting Commercial Books of Enterprises in Electronic Form ("Amendment Communiqué")...
Turkey Corporate/Commercial Law
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The Amendment Communiqué on the Communiqué ("Communiqué") on the Keeping of Non-Accounting Commercial Books of Enterprises in Electronic Form ("Amendment Communiqué"), prepared by the Ministry of Trade and the Ministry of Treasury and Finance, was published in the Official Gazette dated 20 September 2025 and numbered 33023, and entered into force as of its publication date.

Pursuant to the Amendment Communiqué, the board of directors' resolution book and the board of managers' resolution book have been removed from the list of mandatory books to be kept in electronic format. Accordingly, only the share ledger and the shareholders meeting and discussion minutes book are now required to be kept electronically by the companies listed in Article 5 of the Communiqué.

In addition, companies that have been keeping their books in physical form but are now required to keep them electronically are granted an extension until 1 January 2026, to obtain the closing certification of their physical books from a notary public. This must be done together with a board resolution prepared in accordance with the sample set out in Annex-1 of the Communiqué.

For companies that had already transitioned their board of directors' resolution books to electronic format prior to the Amending Communiqué, if they now wish to revert to keeping such books in physical form, they must submit a board resolution to the Ministry of Trade by 1 January 2026. In such cases, the electronic book will be officially closed in the system, and the opening certification of the new physical book will be carried out by a notary public based on the document issued by the Ministry of Trade.

The full text of the Communiqué can be reached via 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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