With the Decision No. 9774 Amending the Decision on the Determination of Companies Subject to Independent Audit (“Decision No. 9774”) published in the Official Gazette dated May 1, 2025, and numbered 32887, the independent audit criteria previously determined by the Decision dated November 30, 2022, and numbered 6434 have been revised once again.
The thresholds used in determining companies subject to independent audit pursuant to Decision No. 6434 were most recently updated by the Decision No. 8313 Amending the Decision on the Determination of Companies Subject to Independent Audit, published in the Official Gazette dated April 6, 2024 (“Decision No. 8313”). With Decision No. 9774, the thresholds set out in Decision No. 8313 have been further increased, and the new thresholds are summarized below:
General Criteria for Being Subject to Independent Audit
The updated thresholds for being subject to independent audit, applicable to companies other than those listed in Annex (I) of Decision No. 6434—which are subject to independent audit regardless of any criteria—and companies considered publicly held under Capital Markets Law No. 6362, as well as those listed in Annex (II) of Decision No. 6434, are provided below.
Former Threshold | Revised Threshold | |
Total Assets | 150 million Turkish Liras | 300 million Turkish Liras |
Annual Net Sales Revenue | 300 million Turkish Liras | 600 million Turkish Liras |
Employee Count | 150 employee | 150 employee |
Companies that exceed the thresholds of at least two of the three criteria above in two consecutive fiscal periods are subject to independent audit.
Companies listed in Annex (II)
Among the companies listed in Annex (II) of Decision No. 6434, those that exceed at least two of the three threshold criteria specified below for two consecutive fiscal periods shall be subject to independent audit starting from the following fiscal period. The updated thresholds for the companies listed in Annex (II) are provided below.
Former Threshold | Revised Threshold | |
Total Assets | 60 million Turkish Liras | 120 million Turkish Liras |
Annual Net Sales Revenue | 80 million Turkish Liras | 150 million Turkish Liras |
Employee Count | 100 employee | 100 employee |
Companies deemed publicly traded under the Capital Markets Law
The thresholds applicable to companies whose capital market instruments are not traded on a stock exchange or other organized markets but are deemed publicly held pursuant to Capital Markets Law No. 6362 remain unchanged. Companies within this scope that exceed at least two of the three threshold criteria set forth below for two consecutive fiscal periods shall be subject to independent audit.
Total Assets | 30 million Turkish Liras |
Annual Net Sales Revenue | 40 million Turkish Liras |
Employee Count | 50 employee |
Decision No. 9774, which entered into force to be applied to fiscal periods starting on or after January 1, 2025, can be accessed at:https://www.resmigazete.gov.tr/eskiler/2025/05/20250501-8.pdf.
Best Regards,
Balay, Eryiğit & Erten
