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Updated Thresholds for Independent Audit

Legal Alerts
Corporate
General

New Developments

The Decision on Amending the Criteria for Determining Companies Subject to Independent Audit (“Decision“), which sets forth the new monetary thresholds regarding the determination of companies subject to independent audit under Article 397 of the Turkish Commercial Code numbered 6102 (TCC), was published in the Official Gazette dated 1 May 2025.

What Amendments does the Decision Introduce?

The monetary thresholds for the determination of the companies subject to independent audit were last updated by the Decision on Amending the Criteria for Determining Companies Subject to Independent Audit published in the Official Gazette dated 6 April 2024 (“Former Decision“). This time, the thresholds have been increased compared to the values in the Former Decision as follows:

Company typeFormer thresholdsNew thresholds
The companies listed in Annexed List II
  1. Total assets of TRY 60 million
  2. Annual net sales revenue of TRY 80 million
  3. Number of employees: 100
  1. Total assets of TRY 120 million
  2. Annual net sales revenue of TRY 150 million
  3. Number of employees: 100
Companies other than those listed above
  1. Total assets of TRY 150 million
  2. Annual net sales revenue of TRY 300 million
  3. Number of employees: 150
  1. Total assets of TRY 300 million
  2. Annual net sales revenue of TRY 600 million
  3. Number of employees: 150

 

Besides, the monetary thresholds for the companies whose capital market instruments are not traded on a stock exchange or other organized markets but are considered publicly traded under the Capital Markets Law remain the same as follows:

Company typeThresholds
Companies whose capital market instruments are not traded on a stock exchange or other organized markets but are considered publicly traded under the Capital Markets Law
  1. Total assets of TRY 30 million
  2. Annual net sales revenue of TRY 40 million
  3. Number of employees: 50

 

However, the main principle that a company must exceed at least two of the new thresholds specified in the table above for two consecutive fiscal periods to be subject to independent audit remains in effect. In any case, all companies enumerated in List I are subject to independent audit, irrespective of the specified criteria.

Conclusion

This Decision came into effect on the date of its publication and will be used to determine the audit obligations of companies for fiscal periods starting on or after 1 January 2025. Accordingly, it is crucial to determine whether companies are subject to independent audit by performing an assessment based on the new thresholds and to complete the procedures for the appointment of independent auditors for those companies that are subject to independent audit.