15 Oct 2025

Current Status Of The Obligation To Maintain Commercial Books In Electronic Form

1. INTRODUCTION With the Communiqué Amending the Communiqué on Keeping Commercial Books Not Related to the Accounting of the Enterprise in Electronic Form, published in the Official Gazette dated September 20, 2025 and numbered 33023 (“Amendment Communiqué”), significant amendments have been introduced to the Communiqué on Keeping Commercial Books Not Related to the Accounting of the Enterprise in Electronic Form, published in the Official Gazette dated February 14, 2025 and numbered 32813 (“Communiqué”).

2. AMENDMENTS INTRODUCED BY THE AMENDMENT COMMUNİQUÉ
  • Regardless of whether the company is subject to the obligation, the Board of Directors’ Resolution Book or the Board of Managers’ Resolution Book has been excluded from the scope of the Communiqué.
  • The books required to be kept in electronic form have been determined only as the Share Ledger and the General Assembly Meeting and Negotiation Book.
  • For companies that, while previously kept physical books, fall within the electronic book obligation, the period to obtain the closure approval of physical books from a notary within the framework of a board resolution has been extended from the two-month period stipulated in the regulation to six months.

3. COMPANIES THAT HAVE SWITCHED TO ELECTRONIC BOOKS AND THE POSSIBILITY OF RETURNING TO PHYSICAL BOOKS

Pursuant to the provisions of the Communiqué, companies that have once started keeping their books in electronic form shall, under normal circumstances, not be allowed to keep these books in physical form again. However, a special arrangement has been introduced for companies that, prior to the entry into force of the Amendment Communiqué, started keeping the Board of Directors’ Resolution Book or the Board of Managers’ Resolution Book in electronic form. Under this arrangement, such companies are granted the option to convert back to physical books.

Accordingly, companies wishing to revert to physical books are required to adopt a board resolution regarding the closure of the electronic books and the transition to physical books, and to submit this resolution to the Ministry of Trade by January 1, 2026.

Based on the document issued by the Ministry, the electronic books shall be closed through the “Electronic Commercial Book System,” and the company may apply to a notary to carry out the opening procedures of its physical books.

Applications to the Ministry of Trade may be submitted through the following channels:
  • Application via Registered Electronic Mail (KEP): Using the address [email protected], with documents signed with a secure electronic signature.
  • Application by Post: Companies may send the relevant documents by post to Söğütözü Mah. 2176. Sk. No:63, 06530 Çankaya/Ankara.
  • Application via e-Government Portal: For the convenience of electronic transactions, applications may be made through the e-Government system.
  • Direct Application: By applying directly to Söğütözü Mah. 2176. Sk. No:63, 06530 Çankaya/Ankara.

The relevant Communiqué can be accessed through the following link:

https://www.resmigazete.gov.tr /eskiler/ 2025/09/20250920-4.htm