Independent Audit Thresholds Raised in Turkey (March 2026)

Turkey’s Public Oversight, Accounting and Auditing Standards Authority (KGK) periodically revises the thresholds that trigger a mandatory independent audit for private companies. In March 2026 a new set of higher thresholds took effect, and the practical result is that most foreign-owned SMEs in Turkey are now outside the audit scope.

Below is a clear breakdown of what changed, who benefits, and what you still must do.

Old vs. new thresholds: what generally changed

The regime uses three criteria — total assets, net sales, and employee count. A company becomes subject to independent audit when it exceeds at least two of the three criteria for two consecutive fiscal years.

With the March 2026 update, each of the three criteria was raised meaningfully. At a high level:

• Total assets threshold: materially increased.
• Net annual sales threshold: materially increased.
• Employee headcount threshold: moderately increased.

We do not publish specific TRY figures here because they are periodically revised. For the exact current thresholds in force for your fiscal year, contact us and we will confirm in writing.

Who was in scope before versus now

Before the revision, a lot of foreign-founded Turkish subsidiaries — e-commerce operations, tech company branches, real estate holding entities — crept over the asset threshold simply because of currency movements or a single large asset (inventory, property, intragroup receivable). Audit obligation followed automatically.

After March 2026, the same companies are in most cases comfortably below the new thresholds. A typical foreign-owned LTD or A.S. with under ~50 employees, regional sales, and normal working capital will likely not be subject to mandatory audit going forward.

Sector-specific regimes still apply. Banks, insurance, capital markets players, and listed companies remain subject to audit regardless of size.

What you still must do, even without an audit

Being outside the independent audit scope does not mean reduced bookkeeping. All Turkish companies must still:

• Keep full statutory books under the Turkish Commercial Code and Uniform Chart of Accounts.
• File monthly VAT (KDV), withholding, and stamp duty returns.
• File quarterly corporate provisional tax and the annual corporate income tax return.
• Maintain transfer pricing documentation if transacting with related parties.
• Observe the scope and disclosure rules that apply to your specific sector.

Bookkeeping is still handled by a licensed SMMM. What changes is whether that SMMM-prepared financial statements additionally go through an independent auditor.

What happens if you are near the threshold

If your company’s assets, revenue, or headcount are within, say, 15% of the new threshold on either side, treat yourself as on the watchlist. Practical steps:

• Monitor the trailing two years of each criterion, not just the current year. The trigger is two consecutive years.
• Pre-plan before year-end: consider timing of intragroup receivables, inventory builds, or large customer prepayments that inflate the balance sheet.
• Talk to us early. Preparing for an audit mid-year is far cheaper than being surprised in Q1.

Why this matters for foreign founders

If you built a Turkish company expecting to need an audit, you may now not. That saves typically tens of thousands of TRY per year and simplifies group consolidation. If you are planning a company formation soon, the new thresholds also shift the calculation on when, not whether, you expand your Turkish footprint.

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Get your audit scope confirmed in writing

Do not guess. Send us your last two years of balance sheets and a current headcount, and we will tell you in a single call whether you are in, out, or borderline. Book a scope-check call.