Independent Audit Thresholds Have Been Updated

Presidential Decision No 11066 was published in the Official Gazette dated 17 March 2026 and numbered 33199 (the “Official Gazette”). This decision amended the Decision on Determining the Companies Subject to Independent Audit dated 29 November 2022 and numbered 6434 (the “Decision”). This amendment revises both the financial thresholds used to determine whether companies are subject to independent audit and the scope of application with respect to certain companies.

1.     Updated Financial Thresholds

Pursuant to Article 3 of the amended Decision, the thresholds applicable to companies that are not specifically listed under the Decision, namely those falling within the scope of the general independent audit obligation, have been updated as follows:

Aside from the increase in the threshold amounts, the existing system remains unchanged, and companies will be subject to an independent audit if at least two of these criteria are exceeded for two consecutive financial years.

2.     Change in Scope

With the amendment to the Decision, item 9 of the list set out under Annex (I), listing companies subject to an independent audit regardless of any threshold, has been revised to include State Economic Enterprises (SEEs) and their subsidiaries, as well as companies established pursuant to Additional Article 1 of the Natural Gas Market Law No 4646 whose share capital is more than fifty per cent owned, directly or indirectly, by SEEs.

3.     Entry into Force

The amendments entered into force on the date of publication – 17 March 2026. The revised thresholds and scope changes will be taken into account in determining whether companies are subject to an independent audit for financial years commencing on or after 1 January 2026.

4.     Conclusion

Following the update to the thresholds, companies are advised to reassess their independent audit obligations and to review the necessary compliance processes for the 2026 financial year.