Significant Amendments to the Decision on the Determination of Companies Subject to Independent Audit (17 March 2026)

With the amendment published in the Official Gazette dated 17 March 2026 and numbered 33199, significant updates have been introduced to Decision No. 6434 on the Determination of Companies Subject to Independent Audit, particularly regarding the scope of companies subject to independent audit and the applicable threshold values.

These amendments are of practical relevance as they directly reshape the scope of the independent audit obligation.

1. Notable increase in general threshold values

Within the scope of the Decision, the threshold values applicable to companies not listed in Annexes (I) and (II) have been significantly increased. Accordingly:

  • The threshold for total assets has been increased from TRY 300 million to TRY 500 million,
  • The threshold for annual net sales revenue has been increased from TRY 600 million to TRY 1 billion.

No changes have been made to the employee threshold, which remains at 150 employees.

This amendment aims to exclude particularly medium-sized companies from the scope of independent audit, while focusing the audit obligation on larger-scale entities.

2. Expansion of the scope under Annex (I)

A significant amendment has also been made to Annex (I), which regulates companies that are directly subject to independent audit regardless of any thresholds.

Accordingly, the following entities have been explicitly included within the scope of independent audit:

  • State Economic Enterprises (SEEs) and their subsidiaries, and
  • Companies established under the Natural Gas Market Law No. 4646, in which more than 50% of the share capital is directly or indirectly owned by SEEs.

This amendment reflects an expansion of the audit scope with respect to state-affiliated companies.

3. Existing structure maintained, but scope rebalanced

The fundamental structure of the Decision has been preserved. Companies continue to be assessed under three main categories:

  • Companies listed in Annex (I) and directly subject to audit,
  • Companies listed in Annex (II) subject to lower thresholds,
  • Other companies subject to general thresholds.

However, by increasing the thresholds applicable to the third category, the overall scope of the system has been rebalanced.

4. Entry into force and application period

The amendments dated 17 March 2026 will apply in determining whether companies are subject to independent audit for financial years starting on or after 1 January 2026.

Accordingly, companies are required to reassess their audit obligations for the 2026 financial year in light of the revised thresholds and scope.

5. Practical implications and assessment

When assessed as a whole, the amendments aim to:

  • Reduce the number of companies subject to independent audit through increased thresholds,
  • Expand the scope for state-affiliated companies, and
  • Focus audit obligations on larger and systemically significant entities.

In this context, companies—particularly those operating near the threshold levels—should carefully reassess their current status by taking into account their asset size, turnover, and number of employees.

 



Author: Müge Şengönül