The Decision Amending the Decision on the Determination of Companies Subject to Independent Audit ("Decision No. 9774") was published in the Official Gazette dated 1 May 2025 and numbered 32887. With Decision No. 9774, the threshold values set forth in the Decision on the Determination of Companies Subject to Independent Audit ("Decision No. 6434") have been updated
Through Decision No. 9774, the criteria for being subject to independent audit applicable to the companies listed under Annex (II) of Decision No. 6434 have been revised. Accordingly, the updated threshold values for companies within this scope are as follows:
- Total assets: TRY 120 million
- Annual net sales revenue: TRY 150 million
- Number of employees: 100
In addition, the threshold values have also been revised for companies that are not listed on a stock exchange or other organized markets and that are not considered publicly held under Capital Markets Law No. 6362 and therefore are not included in Annex (II). For these companies, the updated thresholds are as follows:
- Total assets: TRY 300 million
- Annual net sales revenue: TRY 600 million
- Number of employees: 150
If a company exceeds at least two of these thresholds for two consecutive accounting periods, it will become subject to independent audit as of the following accounting period. In determining whether the thresholds are exceeded, the financial statements of the last two years prepared in accordance with the applicable legislation shall be considered for total assets and net sales revenue. For the number of employees, the average number of employees over the last two years shall be considered.
Another important point is that subsidiaries and affiliates must also be considered in determining whether thresholds are exceeded. In such cases, the sum of the relevant items in the financial statements of the parent company and its subsidiaries—after eliminating intra-group transactions—shall be considered for total assets and net sales revenue. For the number of employees, the sum of the average number of employees over the last two years for both the parent and its subsidiaries shall be considered. For affiliates, the relevant items shall be considered in proportion to the company's shareholding in the affiliate.
Lastly, it should be noted that companies listed in Annex (I) of Decision No. 6434 are subject to independent audit regardless of any threshold criteria.
The amendments to the threshold values set for companies subject to independent audit will enter into force on the date of publication of Decision No. 9774 and will be taken as the basis for determining the audit obligation for accounting periods beginning on or after 01.01.2025.
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.
