TFD Alert – May 2025
Independent Audit Thresholds Updated for 2025
The Presidential Decision amending the criteria for determining which companies are subject to independent audit under Article 397 of the Turkish Commercial Code (No. 6102) was published in the Official Gazette on 1 May 2025 (No. 32887). With this update, the financial thresholds used to assess audit requirements have been significantly raised.
What Changed?
The new thresholds will apply to fiscal periods starting on or after 1 January 2025.
Companies will need to check whether they exceed at least two of the relevant criteria for two consecutive fiscal years.
1. Companies not subject to specific sector regulations
Companies that are not within the scope of specific sector regulations will be subject to independent audit if they satisfy two of the following:
|
Criterion |
Previous Threshold |
New Threshold |
|
Total Assets |
TRY 150 million |
TRY 300 million |
|
Annual Net Sales Revenue |
TRY 300 million |
TRY 600 million |
|
Number of Employees |
150 |
150 (unchanged) |
2. Companies listed in Annex II
This includes companies regulated by the Information and Communication Technologies Authority (BTK), companies managed by the Savings Deposit Insurance Fund (TMSF), and companies with 50% or more municipal ownership.
|
Criterion |
Previous Threshold |
New Threshold |
|
Total Assets |
TRY 60 million |
TRY 120 million |
|
Annual Net Sales Revenue |
TRY 80 million |
TRY 150 million |
|
Number of Employees |
100 |
100 (unchanged) |
3. Public but Unlisted Companies
There are no changes introduced here. The current criteria are as follows:
|
Criterion |
Threshold |
|
Total Assets |
TRY 30 million |
|
Annual Net Sales Revenue |
TRY 40 million |
|
Number of Employees |
50 |
What to Do Now?
This Decision is now in effect and applies to the 2025 financial year. Companies should reassess whether they meet the updated criteria and, if required, start the process for appointing an independent auditor.
For companies that have grown over the last two years, this is a good time to revisit internal controls and compliance frameworks to ensure readiness for audit obligations.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
