The Communiqué on Keeping Non-Accounting Commercial Books of Enterprises in Electronic Format (“Communiqué”), published in the Official Gazette dated 14 February 2025 and numbered 32813, entered into force on 1 July 2025. Under this Communiqué, companies falling within its scope are required to keep commercial books not related to accounting via the Electronic Commercial Book System (ETDS – etds.ticaret.gov.tr).
Which Companies Are Covered by the Communiqué?
Article 5 of the Communiqué sets out the companies that are subject to the obligation to keep books electronically:
a) Companies whose incorporation is registered with the trade registry on or after 1 January 2026.
b) Joint stock companies listed in the first paragraph of Article 5 of the Communiqué on Raising the Capital of Joint Stock and Limited Liability Companies to New Minimum Amounts and on the Identification of Joint Stock Companies Subject to Incorporation and Articles of Association Amendments Requiring Ministry Approval, published in the Official Gazette dated 15 November 2012 and numbered 28468.
Which Commercial Books Must Be Kept Electronically?
According to Articles 4 and 5 of the Communiqué, the following are commercial books that must be kept electronically:
Share ledger
Board of directors’ resolution book
Managers’ resolution book
General assembly meeting and negotiation book
What Should Be Considered During the Transition Period?
Under the provisions of the Communiqué:
Once a company begins keeping books electronically, it may not revert to physical books (Art. 5/4).
Opening and closing approvals are no longer required for books kept electronically (Art. 5/5).
Companies that were previously keeping physical books and become subject to the obligation to switch to electronic books must obtain a closing certification for their physical books from a notary within two months from the date this obligation arises, together with a board resolution in the format provided in Annex-1 of the Communiqué (Art. 9/2).
User guides for the Electronic Commercial Book System are available at:
https://etds.ticaret.gov.tr/Login