Revision of Thresholds for Companies Subject to Independent Audit

Pursuant to the Presidential Decree published in the Official Gazette, the financial
thresholds for determining the scope of companies subject to independent audit under the
Turkish Commercial Code have been revised. Under the amended framework, companies within the general scope will be subject to independent audit if at least two of the following three criteria are exceeded:

• Total Assets: TRY 500,000,000
• Annual Net Sales Revenue: TRY 1,000,000,000
• Number of Employees: 150

The assessment of whether a company is subject to independent audit is based on
exceeding the relevant thresholds for two consecutive fiscal years. Similarly, a company
may exit the scope if the thresholds are not met for two consecutive fiscal years.
The revised thresholds will apply to fiscal periods commencing on or after January 1, 2026.
Accordingly, companies are advised to perform a forward-looking assessment based on
their financial data for the 2024 and 2025 fiscal years to determine their potential audit
status.
In addition, the amendments introduce revisions concerning State-Owned Enterprises
(SOEs) and their subsidiaries, as defined under the relevant legislation.
Considering the updated thresholds, certain companies that were previously outside the
scope of independent audit may now become subject to statutory audit requirements. In this
context, it is advisable for such companies to initiate timely preparations, particularly in
relation to financial reporting processes, internal control frameworks, and audit readiness.