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Criteria for Determining Companies Subject to Independent Audit Have Been Updated

The Decision Amending the Decision on the Determination of Companies Subject to Independent Audit, published in the Official Gazette dated 17 March 2026 and numbered 33199, updates the threshold criteria applicable from accounting periods starting on or after 1 January 2026 and expands the scope of companies covered without any threshold test.

Mar 17, 2026•2 min read

Published by Ozbilen Aykut Attorney Partnership

Gülbin Murat
Gülbin MuratPartner
Lara Yörük
Lara YörükAssociate

Pursuant to Article 397 of the Turkish Commercial Code No. 6102, the Decision Amending the Decision on the Determination of Companies Subject to Independent Audit (the Amending Decision), which introduces amendments to Decision No. 6434 on the Determination of Companies Subject to Independent Audit (the Decision), has been published in the Official Gazette dated 17/03/2026 and numbered 33199.

Under the Decision, companies subject to independent audit are classified into four groups. With the Amending Decision, the criteria applicable to companies that are not included in the annexed lists or otherwise specified under the Decision have been updated. Accordingly, for accounting periods starting on or after 01/01/2026, the companies subject to independent audit are as follows:

  1. Companies subject to independent audit without being subject to any threshold criteria (companies listed in Annex (I) of the Decision).
  2. Companies listed in Annex (II) of the Decision, provided that at least two of the thresholds set out in the Decision are met.
  3. Companies deemed to be public under capital markets legislation but whose capital market instruments are not traded on a stock exchange, provided that at least two of the thresholds set out in the Decision are met.
  4. Companies other than those listed above, provided that at least two of the following thresholds are met:
  • Total assets of TRY 500 million.
  • Annual net sales revenue of TRY 1 billion.
  • Number of employees of 150.

In determining whether the above thresholds are met, the financial data of the company shall be assessed on a standalone basis or together with its subsidiaries and affiliates, and such thresholds must be satisfied for two consecutive financial periods.

In addition, with the Amending Decision, the scope of companies listed in Annex (I), which are subject to independent audit without being subject to any threshold, has been expanded. Accordingly, while previously only state economic enterprises (SEEs) operating under Decree Law No. 233 and their subsidiaries were covered, companies established pursuant to Additional Article 1 of Law No. 4646 and whose more than 50% of capital is directly or indirectly owned by SEEs are now also included within the scope of independent audit.

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