The Communiqué on the Maintenance of Commercial Books Not Related to the Accounting of the Business in Electronic Form (“Communiqué”), which includes important regulations regarding the creation, maintenance, preservation, and submission of commercial books in electronic form, has been published in the Official Gazette No. 32813 dated February 14, 2025.
Within the scope of the regulations introduced in the Communiqué, provisions have been established to allow the maintenance of the share ledger, board of directors’ resolution book, board of managers resolution book, and general assembly meeting and negotiation book in electronic form, while the obligation to keep electronic books has been gradually mandated.
Accordingly, as of July 1, 2025, companies whose establishment and amendments to their articles of association are subject to the approval of the Ministry of Trade, such as banks, financial leasing companies, holdings, insurance companies, independent audit firms, and companies subject to the Capital Markets Law, have been mandated to maintain their books in electronic form.
As of January 1, 2026, all newly established companies shall be required to maintain their books in electronic form.
In this context, companies established before January 1, 2026, and that are not subject to the Ministry of Trade’s approval for their establishment and articles of association amendments, may choose to maintain their books electronically. However, according to the Communiqué, companies that start maintaining their books electronically shall not be permitted to revert to maintaining them in physical form for any reason.
The Communiqué also stipulates that the company’s management body members and managers shall be responsible for ensuring that the books are maintained in the electronic system, the accuracy of the entries, and the potential damage that may arise from any discrepancies between the entries.
You can access the full text of the Communiqué, which will come into effect on July 1, 2025, at
https://www.resmigazete.gov.tr/eskiler/2025/02/20250214-7.htm
Best Regards,
Balay, Eryiğit & Erten
