Regulatory update – Türkiye

The Turkish Ministry of Trade introduced a Communiqué in February 2025 establishing the Electronic Commercial Books System for keeping non-accounting commercial books (e.g., share ledgers, board and general assembly books) electronically. The system aims to digitalize corporate record-keeping and standardize practices across companies.

This Communiqué was amended in September 2025 to remove some books from the scope.

The following books can still be maintained electronically:

• Share ledger (pay defteri)
• General assembly meeting book (genel kurul toplantı defteri) and negotiation book (müzakere defteri)

The following books were removed in the September 2025 amendments:

• Board of directors’ resolution book (yönetim kurulu karar defteri)
• Board of managers’ resolution book (müdürler kurulu karar defteri)

Mandatory Electronic Bookkeeping Applies To:

• Companies registered with the Trade Registry on or after 1 January 2026.
• Certain regulated sectors – in that case, companies have been granted an extension until 1 January 2026 to obtain the notary closing certification.

Voluntary Participation

• Companies not covered by the mandatory list may opt to keep their books electronically.
• Once transitioned, all commercial books must be electronic, and reversion to physical books is not allowed.
• Before switching, companies must obtain a notary closing certification for existing physical books.

Compliance & Sanctions

• The system includes strict user authorization controls (recording, viewing, updating, deleting).
• Noncompliance—such as keeping invalid physical books—can result in administrative fines, invalidation of records, and legal liabilities under the Turkish Commercial Code.