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Business owner issuing an invoice on the e-Document portal after the e-Archive invoice limit was removed

What Is the e-Archive Invoice Threshold in Turkey, and Above What Amount Is It Mandatory?

The e-Archive invoice limit (e-arşiv fatura sınırı) is the amount above which taxpayers not registered for the e-Archive Invoice system must issue an invoice electronically instead of on paper. In 2025 this limit was 3,000 TL including taxes. As of January 1, 2026, the amount threshold was removed for taxpayers keeping books on the balance-sheet basis; these businesses issue every invoice as an e-Archive Invoice. For simplified-method taxpayers and those keeping books on the business-account basis, the 3,000 TL limit continues until December 31, 2026.

In this article we explain how the limit has narrowed over the years, the four situations that make the e-Archive Invoice mandatory, which channel you should use to issue invoices, and the exceptional cases in which a paper invoice is accepted. Our reference is the current consolidated version of Tax Procedure Law (VUK) General Communiqué No. 509 as published by the Revenue Administration (GİB).

Summary

Key Takeaways

  • With VUK General Communiqué No. 573, the e-Archive invoice limit was reduced to 3,000 TL including taxes for 2025, and from January 1, 2026 the amount threshold was removed.
  • Communiqué No. 589, published in the Official Gazette on December 31, 2025, extended the 3,000 TL limit until December 31, 2026 for simplified-method taxpayers and those keeping books on the business-account basis.
  • Taxpayers registered for the e-Invoice system issue invoices to unregistered buyers as e-Archive Invoices, regardless of the amount.
  • Printing on paper an invoice that should have been issued as an e-Archive Invoice triggers a special irregularity penalty equal to 10% of the document amount under Article 353 of the Tax Procedure Law.

Who does the e-Archive invoice limit apply to in 2026?

As of 2026, the limit matters for only two groups of taxpayers: those whose commercial income is determined under the simplified method and those keeping books on the business-account basis. These two groups issue invoices whose total amount including taxes exceeds 3,000 TL as e-Archive Invoices; for invoices of 3,000 TL or less, they may use printed paper invoices until December 31, 2026. From January 1, 2027, the amount will no longer matter for them either.

For companies keeping books on the balance-sheet basis, the situation is clearer. Limited liability companies, joint stock companies and other balance-sheet-basis businesses issue every invoice as an e-Archive Invoice or e-Invoice from January 1, 2026. Almost all capital companies with foreign shareholders fall into this group, so in practice no limit remains for them.

When discussing the limit, pay attention to the phrase “total amount including taxes”. VAT and other taxes on the invoice are included in the calculation. For example, a service of 2,600 TL excluding VAT rises to 3,120 TL once 20% VAT is added and exceeds the 3,000 TL limit. We explain where VAT appears on an invoice and how it is calculated in our article what is VAT as well.

E-Archive invoice limit in 2025 and earlier years

In 2025 the e-Archive invoice limit was applied as 3,000 TL including taxes. This amount was set by Communiqué No. 573, published in the Official Gazette on November 12, 2024, and applied to deliveries and services made from January 1, 2025. The same Communiqué also introduced the provision removing the amount threshold from 2026 onward.

Key figures in the e-Archive Invoice rules

3,000 TLLimit valid until December 31, 2026 for simplified-method and business-account taxpayers
500 thousand TLGross sales revenue threshold for online sellers for 2022 and later
3 monthsMinimum preparation period granted when GİB imposes the obligation by written notice
%10Special irregularity penalty on the document amount for an invoice printed on paper instead of e-Archive

Source: VUK General Communiqués No. 509, 573 and 589; Tax Procedure Law Art. 353

The limit has changed several times since it was first introduced in 2020. Based on the earlier provisions shown in the footnoted current communiqué text published by the Revenue Administration, the timeline is as follows:

Application periodLimit for taxpayers not registered for e-Archive (including taxes)Regulation making the change
From January 1, 202030 thousand TL to final consumers, 5 thousand TL to taxpayersOriginal version of Communiqué No. 509
From Communiqué No. 526 until December 31, 20245 thousand TL; for invoices issued to taxpayers, that year's invoicing threshold under VUK Article 232Communiqué No. 526 (OG 09.02.2021)
January 1, 2025 – December 31, 20253,000 TLCommuniqué No. 573 (OG 12.11.2024)
From January 1, 2026 (balance-sheet basis)No amount thresholdCommuniqué No. 573
January 1, 2025 – December 31, 2026 (simplified method and business-account basis)3,000 TLCommuniqué No. 589 (OG 31.12.2025)
From January 1, 2027 (simplified method and business-account basis)No amount thresholdCommuniqué No. 589

Communiqué No. 573 made one more change. Previously, invoices issued to the same person on the same day were added together, and if the total exceeded the limit, all of them were issued as e-Archive Invoices. This “aggregate assessment” paragraph was repealed; in 2026 the issue has also lost its relevance, since every invoice is already electronic for balance-sheet-basis taxpayers.

E-Archive invoice obligation: 4 situations

The e-Archive invoice obligation does not depend on a single rule. The Communiqué defines four separate routes that bring a taxpayer into the e-Archive Invoice system, and falling into any one of them is enough:

SituationWho it coversAmount thresholdWhen to switch to e-Archive
1. Being an e-Invoice taxpayerAnyone who switches to e-Invoice, whether mandatorily or voluntarilyNoWithin the e-Invoice transition period, together with it
2. Online sales or intermediationIntermediary service providers, classified ad sites, online advertising intermediaries, and those selling through their own website or a marketplaceFor sellers, gross sales revenue of 500 thousand TL for 2022 and laterBy the start of the seventh month of the year following the year in which the threshold is exceeded
3. Invoices of taxpayers not registered for e-ArchiveAll taxpayers not falling into the groups aboveNone in 2026 for balance-sheet basis; 3,000 TL for simplified method and business-account basisPer invoice, at the time of issue
4. Written notice from GİBTaxpayers found to be risky or to have a low level of tax complianceNoWithin the period given in the notice (at least 3 months)

e-Invoice taxpayers

A taxpayer that switches to the e-Invoice system also switches to the e-Archive Invoice system within the same period. This taxpayer issues e-Invoices to buyers registered in the e-Invoice system, and e-Archive Invoices to unregistered companies and final consumers. If both the seller and the buyer are registered for e-Invoice, all invoices between them must be e-Invoices. We cover in detail which turnover levels and sectors make e-Invoice mandatory in our article e-Invoice transition obligation 2026 .

Online sellers and intermediaries

If you sell through your own website, a marketplace or another electronic channel, a separate section of the Communiqué applies to you. For these sales, the e-Archive Invoice must be delivered to the buyer electronically. The invoice shows the website where the sale was made, the payment method and date, the delivery date of the shipment and the carrier's details; it must also include the statement “This sale was made over the internet.”

This section also governs the return process. If the customer wants to send the goods back, they fill in and sign the return section on the invoice printout and send it to the seller together with the goods. Once received by the seller, this document serves in place of an expense voucher (gider pusulası).

Unregistered taxpayers and GİB notice

The third situation is where the limit discussed in this article applies. A taxpayer not registered for the e-Invoice or e-Archive system must still issue the invoice as an e-Archive Invoice when the amount threshold is met. This taxpayer does not have to register for the system but issues the invoice through the portal provided by GİB or through an authorized private integrator.

In the fourth situation, the deciding factor is not turnover or sector but risk analysis. The Revenue Administration may impose the e-Archive Invoice obligation on taxpayers it considers to have low tax compliance by written notice, granting a preparation period of at least 3 months.

If the e-Archive invoice limit no longer applies, which channel do you use to issue invoices?

A taxpayer for whom the e-Archive invoice limit has been removed has two options: GİB's e-Document issuance portal or the system of a private integrator authorized by the Revenue Administration. Paper invoices are no longer an option. Which route suits you depends on how many invoices you issue per month and on your accounting software's integration capabilities.

e-Archive portal or integrator?

For a self-employed professional or small business issuing a few invoices a month, the e-Archive portal is often sufficient. Invoices are created one by one on screen, and the buyer receives a printout or an electronic copy. As the number of invoices grows, manual entry on the portal means doing the work twice alongside the accounting entries and increases the risk of error.

Under the private integrator method, invoices are generated automatically from the accounting or sales software; storage and reporting also run through the integrator's system. A picture we often see among our clients is a company that started 2026 with the portal having to switch to an integrator within a few months. Planning this transition from the start prevents invoice series and account records from having to be set up twice.

Is the buyer registered for e-Invoice?

Before issuing an invoice, you need to check whether the buyer is a registered e-Invoice user. Issuing an e-Archive Invoice to a registered buyer, or trying to send an e-Invoice to an unregistered buyer, both mean the document was issued in the wrong type. The current list of registered users is published at ebelge.gib.gov.tr, and integrator software usually performs this check automatically.

Let's plan your e-Archive transition together

You can request a preliminary review with our expert team to clarify whether the limit applies to you based on your bookkeeping type and invoice volume, and to choose between the portal and an integrator.

When is a paper invoice exempt from penalty?

The Communiqué tolerates printing on paper an invoice that should be issued as an e-Document only in limited cases. In these cases, provided that the legal deadline for issuing the invoice is not missed, no special irregularity penalty is imposed:

  • A failure, outage or maintenance in the systems of GİB or of other public institutions participating in e-Document applications.
  • A failure, outage or planned maintenance in the taxpayer's own system or the private integrator's system, provided it can be proven.
  • Failure or theft of the financial seal or electronic signature device (until a new one is obtained).
  • GİB permitting paper documents to be issued by communiqué, circular or announcement.

No penalty is imposed either when an e-Archive Invoice cannot be issued due to force majeure under Article 13 of the Tax Procedure Law (events beyond your control such as disasters or serious accidents). By contrast, reasons attributable to the taxpayer, such as forgetting the portal password or failing to renew a software subscription, do not fall under these exceptions.

Business owner issuing an invoice on the e-Document portal after the e-Archive invoice limit was removed

What is the penalty for printing an invoice above the limit on paper?

Issuing or receiving as a printed paper invoice an invoice that should have been issued as an e-Archive Invoice is subject to the special irregularity penalty under Article 353 of the Tax Procedure Law. According to the text of the law quoted in the Revenue Administration's Communiqué, the penalty is 10% of the amount that should have been written on the document. The penalty is calculated separately for each document and cannot be less than the minimum amount set in the law.

This minimum amount and the cap on the total penalty in a calendar year are updated each year by the revaluation rate. The penalty is imposed not only on the issuer of the invoice but also on a taxpayer buyer other than a final consumer. In other words, a company that accepts a paper invoice bears the same risk; if you are still receiving printed invoices from a supplier, it is in your interest to question this.

Besides the penalty risk, there is also a bookkeeping risk. Under the Communiqué, an e-Document not issued in line with the prescribed format and standards is not considered a document issued under the law. This may mean that the expense deduction and VAT deduction based on the invoice can be challenged.

Common mistakes when calculating the limit

The mistakes we encounter most often in practice stem less from the limit itself than from the way it is calculated:

  • Looking at the amount excluding VAT: The limit applies to the total amount including taxes; even if the tax base is below 3,000 TL, the amount including VAT may exceed the limit.
  • Not knowing your bookkeeping type: In 2026, the 3,000 TL limit applies only to simplified-method and business-account taxpayers; a business that moves to the balance-sheet basis loses this flexibility.
  • Relying on outdated information pages: Old limits such as 30 thousand TL and 5 thousand TL may still appear online and even on some official information pages; the text to rely on is the current version of the Communiqué.
  • Continuing to use up printed invoice stock: For balance-sheet-basis companies, there is almost no remaining use in 2026 for printed invoices left in stock.

Thresholds and dates may change again with new communiqués. We therefore recommend following the announcements at ebelge.gib.gov.tr at the start of each year. You can find our other articles on tax returns, VAT and e-transformation in the tax legislation category.

What do we check at Akal CPA during an e-Archive transition?

When a business moves to the e-Archive Invoice, we first clarify its bookkeeping type and e-Invoice scope; whether the limit applies depends on these two pieces of information. We then plan the portal or integrator decision according to invoice volume, together with obtaining a financial seal or e-signature and setting up the accounting records. e-transformation and e-Invoice advisory service covers all of these steps.

You can access the footnoted current text of the Communiqué from VUK General Communiqué No. 509 published on GİB's e-Document portal, and the amendment introducing the 2025 and 2026 limits from the text of Communiqué No. 573 .

Let's map out your tailored roadmap together

At Akal CPA, every engagement starts with a preliminary review based on your company's structure and goals. If you would like to work out a tailored roadmap for moving to the e-Archive Invoice and adapting your invoicing to the new rules, contact us.

This content was prepared by the Akal CPA expert team. Since 1975, Akal CPA has provided company formation, accounting, tax and payroll advisory services to domestic and foreign investors in Ankara. The limits and dates in this article are based on VUK General Communiqué No. 509 as amended by Communiqués No. 573 and 589.

This article is for general information only; seek professional advice for your specific situation. The amounts and rates in this article are current as of October 2026; if the e-Archive limit changes with a new communiqué, we will update the article. Last updated: 17.10.2026

Frequently Asked Questions

Can I issue an invoice below 3,000 TL on paper in 2026?

This depends on your bookkeeping type. If you are a simplified-method taxpayer or keep books on the business-account basis, you may use printed invoices for amounts of 3,000 TL or less until December 31, 2026. If you keep books on the balance-sheet basis, every invoice has been issued as an e-Archive Invoice or e-Invoice since January 1, 2026.

Do I need to register for e-Invoice to issue e-Archive Invoices?

Taxpayers who must issue e-Archive Invoices because of the limit and are not within the e-Invoice scope issue them through GİB's e-Document issuance portal or an authorized private integrator. For those who wish to register fully for the e-Archive Invoice system on a voluntary basis, the Communiqué requires first joining the e-Invoice system.

Is there a different limit for invoices issued to final consumers?

No. From 2025, the distinction between final consumers and taxpayers was removed and a single limit began to apply. Under the original 2020 regulation, there were two separate limits: 30 thousand TL for final consumers and 5 thousand TL for taxpayers.

How is an e-Archive Invoice delivered to the buyer?

Under the Communiqué, an e-Archive Invoice is delivered as a paper printout or electronically, at the buyer's request. For online sales, however, the invoice must be delivered electronically. The issuer's copy is in all cases stored electronically.

What should I do if I issued a paper invoice during a system failure?

Failures or maintenance in GİB systems, and failures of your own system that you can prove, are among the exceptions in the Communiqué. In these cases, provided the legal deadline for issuing the invoice is not missed, no special irregularity penalty is imposed. Keeping records and notifications showing the failure makes it easier to prove the situation in a possible tax audit.

Are the e-Archive Invoice and the e-Invoice the same document?

Both have the same legal standing as a paper invoice; the difference lies in the buyer. An e-Invoice is transmitted through GİB between two taxpayers registered in the system. An e-Archive Invoice is issued to companies not registered for e-Invoice and to final consumers.

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