With Circular No. 2026/9, the Social Security Institution has made an important change to Circular No. 2020/8 on administrative fines. The "zero day – zero earnings" exemption applied until now has been abolished.

1. Previous practice

Under the relevant section of Circular No. 2020/8, no administrative fine was applied to monthly premium and service documents, or withholding and social security returns, in which all insured persons were reported with zero premium days and zero earnings subject to premium, even if they were filed late. This was particularly convenient for employers in months of unpaid leave, sick leave or temporary suspension of activity.

2. New practice

With the exemption abolished, documents reporting insured persons with zero days and zero earnings will be treated like any other document. If these documents are filed late or prepared ex officio by the Institution, an administrative fine may be applied under Article 102 of Law No. 5510 depending on the type of document (original/additional) and how it is filed.

3. Entry into force

The change applies to monthly premium and service documents and withholding and social security returns for April 2026 and later months.

4. Assessment

• Declarations for insured persons on unpaid leave, or who did not work at all in the month, must also be made within the legal deadline.
• For workplaces that suspend activity, options such as closing the workplace registration or registering employees' departures should be considered.
• We recommend updating checklists so that zero declarations are not forgotten in the payroll and filing calendar.

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

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