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The Communiqué Amending the Communiqué on Supporting the Conversion of Companies’ Foreign-Sourced Foreign Currency into Turkish Lira (No. 2023/5) (Communiqué No. 2026/11) (the "Amending Communiqué") was published in the Official Gazette dated 1 August 2026 and numbered 33327.
While maintaining the 2% foreign currency conversion support available to companies, the Amending Communiqué substantially revises the conditions for benefiting from the support scheme, the upper limits applicable to foreign currency sales and support amounts, the review and audit procedures, and the sanctions applicable in cases of false declarations or improper use.
The principal amendments introduced by the Amending Communiqué are summarised below, together with their practical implications for companies and intermediary banks.
Conditions for Benefiting from the FX Conversion Support
Companies will continue to receive support equal to 2% of the amount converted into Turkish lira, provided that they request the support when selling their foreign currency proceeds originating from abroad to the Central Bank of the Republic of Türkiye ("CBRT") through an intermediary bank and do not exceed the foreign exchange position ratio to be determined by the CBRT.
The conversion rate is defined as the foreign exchange buying rate announced by the CBRT, in accordance with the procedures and principles to be determined by the CBRT, on the date the relevant foreign currency is sold. The intermediary bank will determine whether the foreign currency qualifies as foreign-sourced, while companies must demonstrate to the intermediary bank that their foreign exchange position ratio remains below the prescribed threshold before benefiting from the support.
The Amending Communiqué also expressly provides that foreign currency sold to the CBRT may not be returned under any circumstances. Accordingly, if a support application is subsequently rejected or the company fails to submit the required information and documentation, the completed foreign currency sale cannot be reversed.
Upper Limits on FX Sales and Support Amounts
The CBRT may impose upper limits on both the amount of foreign currency that companies may sell under the support scheme and the amount of support they may receive.
The applicable foreign currency sale limits will be determined by the CBRT based on a methodology taking into account company profitability and labour costs as indicators of value added.
Support applications submitted by companies exceeding the applicable limits will not be accepted. Companies should therefore verify, before applying, not only their foreign exchange position ratios but also any company-specific limits introduced through the CBRT's implementation guidelines.
Support for Supplier Companies in Intermediated Export Transactions
Under intermediated export arrangements, foreign currency brought into Türkiye by Foreign Trade Capital Companies, Sectoral Foreign Trade Companies and other intermediary exporters may be sold on behalf of supplier companies.
In such cases, compliance with the foreign exchange position ratio must be demonstrated by the supplier company, while the intermediary bank will transfer the support amount directly to the supplier company's account.
For the purposes of the Amending Communiqué, the foreign currency sale will be deemed to have been carried out by the supplier company.
False Declarations and Improper Use
Where it is determined that the declaration regarding the foreign exchange position ratio is inaccurate, or that support has been obtained through false information or documentation or otherwise used improperly or contrary to its intended purpose, the support amount will be recovered together with the relevant foreign exchange difference accrued during the applicable period.
Interest will also accrue from the payment date until the date of determination at the highest overnight lending rate announced by the CBRT and applicable on the determination date. Recovery will be carried out through the intermediary banks.
In addition, the relevant company's applications for FX conversion support and CBRT-funded loans may be suspended for a period determined by the CBRT, taking into account the amount involved and any repeated violations. The CBRT may also decide to file a criminal complaint where appropriate.
Extension of Sanctions Across the Corporate Group
The Amending Communiqué defines "control of a company" as directly or indirectly holding at least 50% of a company's shares or voting rights, or possessing the right to appoint at least 50% of the members of its board of directors.
Until the relevant recovery amount has been paid in full, the sanctions will also extend to:
- companies controlled by the breaching company;
- companies controlling the breaching company; and
- other companies controlled by the same natural or legal persons.
Accordingly, a compliance failure affecting a single group company may also restrict the access of other companies within the same corporate group to the CBRT's support scheme and credit facilities. This amendment highlights the importance of implementing centralised compliance controls at group level.
Obligations of Intermediary Banks
Intermediary banks are required to notify the CBRT of suspicious transactions relating to the support scheme and to take all necessary measures to transfer to the CBRT, within one month, any amounts determined by the CBRT.
Should the relevant amount not be transferred within the prescribed period, the CBRT may recover it directly from the intermediary bank's accounts maintained with the CBRT.
Intermediary banks may also charge commissions for transactions under the scheme, provided that such commissions do not exceed the maximum rate determined by the CBRT.
Review and Audit Regime
The CBRT may require companies to submit specified information and documentation either through the intermediary bank or directly to the CBRT.
Companies failing to provide the requested documentation will not be entitled to benefit from the support scheme. Where the relevant foreign currency has already been sold, the transaction will remain irrevocable.
The CBRT may review companies on the basis of submitted information or information obtained from other sources and may conduct the review itself or through the intermediary bank. No support payments will be made while the review remains ongoing.
If the review identifies improper use, false declarations or misuse of the support scheme, the support application will be rejected and the applicable recovery and sanction mechanisms will apply. If no irregularity is identified, the support application will proceed upon completion of the review.
Transitional Provisions and Entry into Force
The duration of the support scheme has been extended from 31 July 2026 to 31 January 2027.
However, only the provision extending the duration of the scheme entered into force on 1 August 2026. The remaining amendments will become effective on 1 October 2026.
The former provisions will continue to apply to breaches of undertakings not to purchase foreign currency given before the Amending Communiqué entered into force.
Assessment and Conclusion
Although the Amending Communiqué preserves the existing 2% FX conversion support, it introduces a significantly more robust compliance framework centred on company-specific financial indicators, foreign exchange position ratios, control relationships and enhanced documentary review.
In particular, the extension of sanctions across corporate groups, the recovery mechanism based on exchange rate differences and the CBRT's highest overnight lending rate, and the potential restrictions on access to CBRT-funded credit facilities mean that applications can no longer be assessed solely at the level of the individual applicant company.
Companies intending to benefit from the support scheme should therefore verify, prior to submission, their foreign exchange position ratios, applicable company-specific limits, documentation evidencing the foreign source of the relevant foreign currency and intra-group control structures. They should also ensure that declarations and supporting documentation submitted to intermediary banks are maintained within a robust and auditable compliance framework.
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.
