Recent Development
The Capital Markets Board of Türkiye (the “CMB”) had previously introduced measures facilitating share buybacks pursuant to its resolution dated 19 March 2025 and numbered 16/531 (the “2025 Resolution”). With its resolution dated 22 September 2026 and numbered 60/1711 (the “2026 Resolution”), the CMB has introduced an additional facilitation by providing that the total monetary cap will no longer apply. Our legal alert regarding the 2025 Resolution is available here.
What’s New?
Under the 2026 Resolution, in respect of share buybacks to be effected pursuant to the 2025 Resolution, the total monetary cap set out in Article 9(3) of the Communiqué on Share Buybacks will not apply. Accordingly, until further notice, the provision stipulating that the total acquisition value for the buyback shares may not exceed the total amount of sources available for profit distribution under the CMB regulations will not apply.
Conclusion
The 2026 Resolution permanently removes one of the key quantitative limitations on share buyback programs conducted under the facilitated share buyback regime introduced by the 2025 Resolution, thereby expanding the financial flexibility available to public companies seeking to carry out share buybacks.

