ELECTRONIC LEDGER TRANSITION – UPDATED PRACTICAL GUIDE
ELECTRONIC LEDGER TRANSITION – UPDATED PRACTICAL GUIDE
INTRODUCTION
This guide is prepared in accordance with the Communiqué on Keeping Commercial Books Not Related to the Accounting of the Business in Electronic Environment (within the scope of the Turkish Commercial Code and Tax Procedure Law)
published within the scope of the latest updates and regulations made in this communiqué
It has been prepared in light of the Tax Procedure Law Circular No. 2025/15.
With the Circular, especially the books that must be kept electronically as of 1 July 2025 and the application principles have been updated.
In addition, it is also possible to keep the inventory book electronically upon request.
1. Sample Company Information
– Trade name: Örnek A.S.
– Type of company: Incorporated company
– Date of establishment: 1 January 2024
– Books to be kept electronically:
– Share Ledger
– Board of Directors Decision Book
– General Assembly Meeting and Deliberation Book
2. MERSIS Registration
The company must be registered in the trade registry and have a MERSIS (Central Registry Registration System) number. If there is no MERSIS number, registration is made through the trade registry directorate.
To check https://mersis.gtb.gov.tr
3. Provision of Electronic Signature or Financial Seal
A secure electronic signature (e-signature) in the name of the company official (e.g. chairman of the board of directors) or a financial seal in the name of the legal entity must be provided.
Application addresses:
– e-signature: Türktrust, E-Güven, E-imzaTR etc.
– financial seal: https://kamusm.bilgem.tubitak.gov.tr
4. Selection and Installation of Compatible Software
Software approved by the Ministry of Commerce should be used for the creation and storage of electronic books.
Popular software: Logo, Mikro, Foriba, E-Logo, Edoksis etc.
5. Creation and Signing of Books
Electronic books are created in the system. After entering the required information, it is signed with electronic signature / financial seal and sealed with time stamp.
6. Storage and Backup
Electronic books should be kept in digital media for 10 years and should also be backed up. It can be exported in PDF/XML format when necessary.
7. Transactions with the Trade Registry Office
In some cases, notification or registration may be required. It is possible to process automatically via MERSIS.
8. Current Obligation Start Date
– As of 1 July 2025, capital companies and merchants registered in the trade registry,
– Commercial books that are not related to accounting (share ledger, board of directors’ decision book, general assembly book, etc.) must be kept electronically.
– Prior to this date, there is no mandatory obligation to keep electronic books; however, businesses may optionally keep electronic books.
9. Sample Timetable
| History | Operation |
| 01.01.2024 | Company established, MERSIS number obtained |
| 15.01.2024 | e-signature/fiscal seal application was made |
| 01.02.2024 | Software installation completed |
| 10.02.2024 | First board resolution entered and stored in the electronic ledger (optional) |
| 01.07.2025 | Electronic bookkeeping obligation started and books started to be kept electronically |
10. Practical Notes
– The ledgers cannot be intervened manually.
– Each transaction is recorded with a unique time tag.
– The system should be structured to be ready for Ministry inspections.
- Criminal Liability and Sanctions
- Businesses that do not keep the books that must be kept electronically within the scope of the Communiqué in accordance with the specified time and procedures,
Pursuant to Article 562 of the Turkish Commercial Code, the Company may be subject to a fine. - In addition, improperly kept or not kept books may be subject to penalties before the courts and official authorities.
may not be accepted as evidence. - Therefore, it is important to keep the books in electronic environment in a timely manner and in accordance with the legislation.