By the Amendment Decision on the Determination of Companies Subject to Independent Audit (the “Amendment Decision”), published in the Official Gazette dated March 17, 2026 and numbered 33199, certain amendments have been made to Decision No. 6434 on the Determination of Companies Subject to Independent Audit (the “Decision”), which was published in the Official Gazette dated November 30, 2022 and numbered 32029.
The threshold values used to determine companies subject to independent audit have been updated by the Amendment Decision, and certain public companies have been included within the scope of independent audit. These changes will apply to accounting periods starting on or after January 1, 2026.
What Are the Changes Introduced by the Amendment Decision?
The Amendment Decision updated the threshold values used to determine whether a company is subject to independent audit. The updated thresholds, presented on a comparative basis, are as follows:
| Thresholds Prior to the Amendment Decision |
New Thresholds Introduced by the Amendment Decision |
- Total assets of TRY 300 million
- Annual net sales revenue of TRY 600 million
- Number of employees of 150
|
- Total assets of TRY 500 million
- Annual net sales revenue of TRY 1 billion
- Number of employees of 150
|
Companies that exceed at least two of the above thresholds in two consecutive accounting periods will be subject to independent audit.
The thresholds have not been updated for companies listed in Annex (II) or for companies that are not traded on a stock exchange or other organized markets but are considered publicly held under the Capital Markets Law.
Finally, under the Amendment Decision, state economic enterprises (“
SEEs”) and their subsidiaries falling within the scope of Decree Law No. 233 dated June 8, 1984, as well as companies established domestically within the scope of Article 1 (Additional) of the Natural Gas Market Law No. 4646 dated April 18, 2001,
in which more than 50% of the capital is directly or indirectly owned by SEEs, will be subject to independent audit regardless of any threshold criteria.
Conclusion
Although the Amendment Decision entered into force on its publication date, it will be applied in determining whether companies are subject to independent audit for accounting periods starting on or after January 1, 2026. Therefore, it is important for companies to review their audit obligations within the framework of the updated threshold values and relevant exemptions and, if they are subject to audit, to complete the independent auditor appointment process in a timely manner and in compliance with the applicable legislation.
Kayra Menekşe, Associate
Cemile Tekdemir, Associate
Ece Koçlar, Trainee Lawyer