Client Alert:

Increased Administrative Fines under the Turkish Commercial Code for 2026

Increased Administrative Fines under the Turkish Commercial Code for 2026

The Ministry of Trade has published the “Communiqué on Administrative Fines to be applied in 2026 under the Turkish Commercial Code (“TCC”) No. 6102” in the Official Gazette dated 17 December 2025.

The TCC establishes a regulatory framework to ensure transparency, accountability and fair competition in the commercial environment. To enforce these principles, the TCC prescribes administrative fines for specific violations under Articles 33, 38, 51 and 562.

These fines generally relate to failures to:

  • comply with trade registry obligations;
  • comply with regulations governing the use and display of trade names;
  • keep commercial books as required, complete the approval procedures for commercial books before notary offices and provide auxiliary tools to read documents where such documents are required to be kept in image or other electronic data formats;
  • prepare financial statements in accordance with Turkish Accounting Standards;
  • notify the issue of share certificates;
  • notify the transfer of bearer share certificates.

For 2026, the administrative fines will be updated based on the revaluation rate of 25.49%, determined by the Ministry of Treasury and Finance, to be effective from 1 January 2026. Please see the table below for the fines applicable for each violation.

Violation Fine - 2025 (TRY) Fine - 2026 (TRY)
Article 33 (2): Failure to apply for the registration, modification or deletion of trade registry records within statutory time limits. 17.686 22.194
Article 38 (1): Making false declarations to the Trade Registry Directorate for registration and recording purposes. 35.416 44.443
Article 51 (2): Unlawful use of commercial title. 35.416 44.443
Article 562 (1) (subparagraph a): Failure to duly keep commercial books. 70.920 88.997
Article 562 (1) (subparagraph b): Failure to obtain copy of the commercial documents. 70.920 88.997
Article 562 (1) (subparagraph c): Failure to obtain the closing approvals (specifically for journal and inventory books) or renewal approvals within statutory deadlines. 70.920 88.997
Article 562 (1) (subparagraph d): Keeping records that do not reflect the true financial status or comply with accounting standards. 70.920 88.997
Article 562 (1) (subparagraph e-f): Irregularities in the preparation of the inventory and opening balance sheets and failure to provide auxiliary tools to read documents where such documents are required to be kept in image or other electronic data formats. 70.920 88.997
Article 562 (2): Failure to prepare financial statements in accordance with Turkish Accounting Standards. 70.920 88.997
Article 562 (13) (subparagraph a): Failure to notify the issue of share certificates or the transfer of bearer share certificates. 138.498 173.801

Companies and commercial actors are advised to review their compliance status with their statutory obligations, including but not limited to trade registry filings, technological requirements and auditing obligations, in view of the substantial increase in financial liability for non-compliance starting from 1 January 2026.

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