Criteria for Mandatory Independent Audit under the Turkish Commercial Code – 2026

Decree No. 11066, amending Presidential Decree No. 6434 on the determination of companies subject to independent audit, was published in Official Gazette No. 33199 of 17 March 2026 and entered into force. The new thresholds will be used to determine whether companies are subject to audit for financial years beginning on or after 1 January 2026.

New general thresholds

Companies not included in the lists annexed to the Decree and not traded on the capital markets are subject to independent audit if they exceed at least two of the three criteria below in two consecutive financial years. The criteria are assessed for the company alone or together with its subsidiaries and associates.

How the thresholds have changed over the years

Companies subject to audit regardless of thresholds

For companies listed in the annexes to the Decree — such as entities subject to CMB, BRSA and insurance legislation, Borsa Istanbul members, licensed warehouses, certain media service providers, and companies subject to EMRA and ICTA regulation — different (lower) thresholds or an audit obligation regardless of thresholds apply. The position of these companies should be assessed separately.

What should you do?

• Compare your total assets, net sales and average headcount for the 2024 and 2025 financial years against the new thresholds.
• If you remain subject to audit, appoint and register your auditor on time.
• If you fall out of scope, consider whether a voluntary audit is needed under loan agreements or shareholder agreements.

Take the audit requirement test →