Threshold Values For Statutory Independent Audit Updated For 2025

The threshold values to be used in determining whether companies will be subject to independent audit under the Turkish Commercial Code No. 6102 (the “TCC”) for financial year starting on or after January 1^st 2025 have been updated with the Presidential Decree published in the Official Gazette dated May 1^st 2025 and numbered 32887.

Accordingly, the general thresholds for being subject to independent audit for companies other than those specifically listed in the annex of the Decision on the Determination of Companies Subject to Independent Audit (the “Decision”) are as follows:

Updated thresholds for companies listed under Annex (II) of the Decision, are as follows:

No changes have been made to the thresholds applicable to companies that do not have capital market instruments traded on stock exchange or other organized markets but are considered publicly held under the Capital Markets Law. The applicable thresholds for these companies remain as follows:

In this context, companies that exceed any two of the above thresholds in two consecutive financial years will be subject to an independent audit as of the following financial year.

Key Takeaways

Since the assessment of thresholds will be based on companies' financial statements and the average number of employees of the last two years, companies should compare their last two years' financial data against the new thresholds, and, accordingly, companies identified to fall under independent audit in the next financial year must ensure timely appointment and registration of their independent auditor. Additionally, it should be noted that companies that were previously subject to an independent audit under previous threshold values, may fall outside the scope following the update, whereas growing companies may now fall within the scope under the new thresholds.

Lastly, in determining whether the threshold values have been exceeded, companies must also take into account their subsidiaries and affiliates. For companies with subsidiaries and affiliates, the consolidated figures in the financial statements of the parent company and subsidiaries (excluding any intra-group transactions, where applicable) should be taken into account for total assets and annual net sales, while the average number of employees over the last two years for both parent and subsidiaries should be taken into account for the number of employees. For subsidiaries, the relevant figures should be taken into account in proportion to the company's shareholding in the subsidiary.

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.