By Presidential Decree No. 9774, published in the Official Gazette dated 1 May 2025, the threshold criteria to be used in determining companies subject to independent audit have been updated and entered into force to be applicable as of the 2025 fiscal period.
Pursuant to Article 397 of the Turkish Commercial Code No. 6102, capital companies that meet certain criteria are required to undergo independent audit to provide reasonable assurance as to whether their financial statements are prepared in accordance with the Turkish Accounting Standards.
The aforementioned regulation aims to ensure a transparent and reliable investment environment, to enable shareholders and third parties to make more informed decisions regarding companies, and to enhance the quality of financial reporting by companies.
In this context, the first regulation regarding the determination of companies subject to independent audit was introduced by the Council of Ministers Decision No. 2012/4213, published in the Official Gazette dated 23 January 2013 and numbered 28537. This regulation was subsequently updated by Presidential Decree No. 6434 titled “Presidential Decree on the Determination of Companies Subject to Independent Audit.” The threshold values related to total assets, net sales revenue, and number of employees—used to determine whether a company is subject to audit—have been gradually and predictably revised over the years with the aim of expanding the scope of audit to cover a broader range of companies.
Within this framework, taking into account current economic conditions and practical requirements, the threshold values applicable to companies subject to general audit criteria and those listed in Annex (II) of the Decree have been re-evaluated and amended by Presidential Decree No. 9774, published in the Official Gazette dated 1 May 2025. The new regulation has entered into force to apply to fiscal periods beginning on or after 1 January 2025.
Under the amendment, companies subject to general audit criteria as well as those listed in Annex (II) of Presidential Decree No. 6434 shall be subject to independent audit as of the 2025 fiscal period, provided that they individually or together with their subsidiaries and affiliates meet at least two of the newly established threshold criteria in each of the 2023 and 2024 fiscal periods.
It is possible that the threshold criteria for independent audit may be revised again in the future. In line with the objectives of increasing economic scale and aligning with international practices, the introduction of stricter audit requirements may be brought to the agenda.