Regulatory Update on Keeping Commercial Books Electronically

“The Communiqué on Keeping Commercial Books Not Related to the Accounting of the Enterprise in Electronic Environment” was published in the Official Gazette dated February 14 2025. This communiqué mandates the keeping of certain commercial books in electronic form and establishes the implementation principles.

The communiqué allows the following books to be kept in electronic form:

  • Share Ledger
  • Board of Directors Resolution Book
  • Board of Managers’ resolution book
  • General Assembly Meeting and Negotiation Book

The obligation to keep electronic books will be implemented gradually:

  • As of July 1, 2025, companies subject to the Capital Markets Law, holdings, banks, insurance companies, and joint-stock companies whose establishment and amendments to the articles of association are subject to the approval of the Ministry of Trade must keep these books in electronic form.
  • As of January 1, 2026, all newly established companies will be required to keep their books in electronic format.
  • Existing companies can voluntarily transition to the system, but once a company switches to electronic books, it will no longer be allowed to revert to physical books.

For newly established companies, books will be created in the electronic system simultaneously with their registration in the trade registry. Companies currently keeping physical books but wishing to transition to the electronic system can do so by closing their physical books with notary approval. Electronic book users will be authorized by the company management, and their information will be recorded in the MERSIS system.

In companies that transition to the electronic environment system, members of the management body and executives will be responsible for the accuracy of book records under Article 553 of the Turkish Commercial Code No. 6102. The keeping, storage, and audit of books will be carried out through the Electronic Book System established by the Ministry of Trade. Electronic book records will be legally valid, and system records will be considered in official audits. However, the obligation to store physical book records from previous periods will continue.

You can access the full text of the Communiqué published in the Official Gazette here.