Independent Audit Thresholds in Turkey: Is Your Company in Scope?

The conditions for being subject to independent audit are the business activity and size criteria, set by Presidential Decree No. 6434, that determine whether a capital company must have its financial statements audited by an authorized auditor. In short, there are two routes: some companies are in scope directly because of their field of activity, while others come into scope when they exceed the thresholds for at least two of total assets, net sales revenue and number of employees in two consecutive fiscal periods.

We explained what an audit is, how the auditor is selected and the types of opinion in our what is an independent audit article. This article focuses on a single question: is your company within the scope of audit for the 2026 fiscal period or not?

What determines whether a company is subject to independent audit?

The scope is set by a Presidential Decree issued under Article 397 of the Turkish Commercial Code. The text in force today is Decree No. 6434 published in the Official Gazette dated November 30, 2022; it was amended in 2024, 2025 and 2026. The Decree divides companies into three groups: those in scope without criteria, those subject to thresholds and those excluded from scope.

The Decree concerns only capital companies, that is, joint stock companies, limited liability companies and partnerships limited by shares. Sole proprietorships and general partnerships are not covered by this regulation. The implementation details are set by the Public Oversight, Accounting and Auditing Standards Authority (KGK) in its Procedures and Principles.

So when assessing your own situation, you need to look at three documents together: the current version of Decree No. 6434, the two lists annexed to the Decree and KGK’s Procedures and Principles. If you are curious about the authority’s duties and powers, see our what is KGK article.

Companies subject to audit without size criteria

Companies on List (I) annexed to the Decree are subject to audit regardless of their size. What matters here is not the figures but the company’s field of activity and the regulator it reports to. The main headings of the list are:

• Investment firms and portfolio management companies regulated and supervised by the Capital Markets Board, and joint stock companies whose shares or other capital markets instruments are traded on the stock exchange,
• Institutions supervised by the Banking Regulation and Supervision Agency (BDDK), such as banks and financial leasing, factoring, financing and asset management companies,
• Insurance, reinsurance and pension companies,
• Authorized institutions licensed to operate in Borsa İstanbul markets, and licensed warehouse operators and general warehouses,
• Media service providers holding certain broadcasting rights or licenses,
• Companies that hold a license, certificate or authorization from the Energy Market Regulatory Authority and have an audit obligation under that authority’s regulations,
• Payment institutions and electronic money institutions supervised by the Central Bank,
• State-owned enterprises (KİT) and their subsidiaries.

Decree No. 11066 expanded this last item. From 2026, companies established in Turkey under Additional Article 1 of Natural Gas Market Law No. 4646 and more than 50% of whose capital is owned directly or indirectly by state-owned enterprises have also been added to the list.

Independent audit criteria: three criteria and the 2026 thresholds

For companies not on List (I), there are three independent audit criteria: total assets, annual net sales revenue and number of employees. Which threshold applies depends on which group the company falls into. The table below shows the values applicable for the 2026 fiscal period:

The rule is the same in every group: the thresholds for at least two of the three criteria must be exceeded in two consecutive fiscal periods. Exceeding the threshold by a very large margin on a single criterion does not bring the company into scope if the other two are below the threshold.

Companies subject to the general criteria

Most companies with domestic or foreign shareholders fall into this group. Under Decree No. 11066 published in the Official Gazette dated March 17, 2026, the total assets threshold rose from 300 million TL to 500 million TL and the net sales revenue threshold from 600 million TL to 1 billion TL. This means an increase of about 67% in both amounts. The employee threshold remained at 150.

Companies on List (II)

List (II) is a narrower group. It includes companies regulated and supervised by the Information and Communication Technologies Authority (excluding call centers), subsidiaries of the Savings Deposit Insurance Fund (TMSF) and companies whose management it has taken over, and companies at least 50% of whose capital is owned by municipalities. For these companies, the thresholds set in 2025 are 120 million TL, 150 million TL and 100 employees.

How have independent audit thresholds changed over the years?

Independent audit thresholds have been raised every year for the last four years. So a table or advisor’s note from previous years may not reflect today’s position. For companies subject to the general criteria, the changes are as follows:

The practical takeaway from the table is this: thresholds are usually announced after the fiscal period has begun, in the first months of the year. The 2026 thresholds were also published in March but apply to periods beginning on January 1, 2026. Waiting for the new year’s decision when planning the choice of auditor may compress your timeline.

How is the two consecutive fiscal periods rule applied?

When checking scope for a fiscal period, you take the thresholds applicable for that period and apply them to the figures of the two preceding fiscal periods. According to the explanation in KGK’s Procedures and Principles, for the 2026 period the 2026 thresholds are compared with the data for the 2024 and 2025 fiscal periods. If at least two criteria were exceeded in both periods, the company is subject to audit for 2026.

The KGK decision published in the Official Gazette dated May 7, 2026 brought important clarity to this rule. The two criteria exceeded in consecutive periods no longer have to be the same criteria. The same decision repealed provisional Articles 2, 3 and 4 of the Procedures and Principles.

Let’s look at a hypothetical example. Consider a limited liability company subject to the general criteria:

This company exceeded the asset and employee thresholds in 2024 and the asset and revenue thresholds in 2025. Although the pairs of criteria differ, two criteria were exceeded in each period, so the company is subject to audit for the 2026 fiscal period.

Which figures are used to calculate the thresholds?

Under Article 5 of Decree No. 6434, total assets and net sales revenue are taken from the financial statements for the last two years prepared under the legislation applicable to the company. For the number of employees, the average number of employees in the relevant year is used, not the headcount at year-end.

Inflation adjustment is a separate question mark. Under KGK’s updated provisional Article 1, for periods in which inflation accounting is applied under the relevant TAS (TMS), total assets and net sales revenue are taken from the financial statements for that period approved at the general assembly. If there is doubt as to which statements should be used, this provision should be checked before building the calculation on a single set of statements.

Are subsidiaries and associates taken into account?

Yes. Under the Decree, whether the thresholds are exceeded is assessed together with the company’s subsidiaries and associates. For subsidiaries, the line items of the parent and the subsidiary are added together and intra-group transactions, if any, are eliminated. For associates, the associate’s figures are added in proportion to the company’s share in the associate.

This rule is especially important for foreign groups operating in Turkey through more than one company. A company that looks small on its own may exceed the thresholds together with a subsidiary under the same umbrella.

When does a company leave independent audit?

A company that came into audit because it exceeded the thresholds leaves the scope in one of two ways. The first is remaining below the thresholds for at least two criteria in two consecutive fiscal periods. The second is falling 20% or more below the threshold values on at least two criteria in a single fiscal period. In both cases, the exit takes effect from the following fiscal period.

KGK’s 2026 amendment introduced the same flexibility on the exit side: the two criteria below the threshold in two consecutive periods do not have to be the same. The rule of assessment together with subsidiaries and associates also applies on exit.

Higher thresholds may change the status of some companies that were in scope in the previous period. We recommend making this assessment company by company, reading the entry and exit provisions together. A company that assumes it has left the scope early and does not appoint an auditor may later face the risk that its financial statements are deemed not to have been legally prepared.

Companies excluded from scope

The Decree excludes certain companies from scope regardless of their size. Companies subject to Law No. 4046 on Privatization Implementations, except those in the first eight items of List (I), fall into this group. Companies at least 50% of whose capital is owned directly or indirectly by the state, special provincial administrations, foundations established by law and other public institutions are also excluded, except those listed in the lists.

The third group is savings financing companies whose liquidation has been ordered by BDDK decision and is carried out by committees appointed by TMSF. These exceptions are interpreted narrowly; a privately owned company generally cannot benefit from them.

Annual checklist for companies subject to independent audit

You need to recheck every year whether you are among the companies subject to independent audit. The mistake we see most often in practice is treating the previous year’s result as permanent. The steps below make this check a routine:

1. Determine your group. Clarify whether the company is on List (I), on List (II), among those deemed publicly held or under the general criteria.
2. Confirm the current thresholds. Check the Presidential Decree in force and KGK announcements for the fiscal period you are assessing.
3. Extract the figures for the last two periods. Take total assets and net sales revenue from the relevant financial statements and the average number of employees from payroll records.
4. Add the group structure. Add up the line items of subsidiaries and include associates in proportion to your share.
5. Document the result. Keep the calculation and its basis in writing; if you are in scope, plan the choice of auditor for the first months of the period.

KGK publishes its announcements on independent audit on its own website. Given that threshold changes may appear in the Official Gazette as late as mid-year, it is useful to follow these announcements in the first quarter.

How does Akal CPA support the scope assessment?

In companies with foreign shareholders, the scope question often becomes complicated because of the group structure. The parent company’s consolidation calendar, the figures of subsidiaries in Turkey and inflation adjustment come together in the same calculation. At Akal CPA, we build this calculation with supporting documents and present the result to management in writing.

If you are in scope, we plan the audit process within the framework of independent audit services . For companies to which we provide accounting services, independence rules mean we work not as the auditor but on the preparation side. For other guides on reporting and incentives, see our investment guide category.

Last updated: 17.10.2026