Decision No. 6434, which determines the companies subject to independent audit under the Turkish Commercial Code, has been amended by Presidential Decision No. 11066. The amendment raises the total assets and net sales thresholds applied to companies not listed in the annexes to the Decision and resets the number of employees criterion.

1. New thresholds

2. Rule for becoming subject to independent audit

Companies not included in lists (I) and (II) annexed to the Decision become subject to independent audit from the following accounting period if they exceed at least two of the three criteria above in two consecutive accounting periods.

Separate, lower thresholds, or an audit obligation regardless of thresholds, continue to apply to listed companies, banks, insurance companies and companies in the sectors listed in the annexes to the Decision.

3. Entry into force and application period

The amendment entered into force on 17.03.2026 and will be applied in determining whether a company is subject to independent audit for accounting periods beginning on or after 01.01.2026.

4. Assessment

• With the higher thresholds, some medium-sized companies may fall outside the scope of independent audit from the 2026 accounting period.
• We recommend that companies compare their 2024 and 2025 financial statements with the new thresholds to determine their 2026 audit status and review existing audit contracts accordingly.
• Even if a company falls outside the scope of independent audit, an audit report may still be requested by shareholders, lenders or under incentive legislation.

This circular is for general information only. Please contact us about your specific situation. The Turkish original is available here.

Altis Danışmanlık

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