How Will the e-Invoice Obligation Change in 2026?

With the regulation published on January 22, 2022 by the Gelir İdaresi Başkanlığı, the scope of the e-Invoice and e-Archive Invoice systems was expanded. Within this framework, the revenue threshold used to determine mandatory transition was set at 3 million TRY, and this limit remains valid in 2026.

According to the current legislation, taxpayers whose gross sales revenue reached 3 million TRY or more in 2022 and the following years (2023, 2024, and 2025) were required to join the e-Invoice and e-Archive Invoice systems. For these businesses, the mandatory transition to the e-Invoice system was completed as of July 1, 2025, and the obligation continues uninterrupted in 2026.

Additionally, businesses that are required to adopt the e-Invoice system must also transition to the e-Ledger (e-Defter) system. Accordingly, for companies that switched to e-Invoice under the mandatory scope, the e-Ledger obligation came into force on January 1, 2026.

In summary, the 3 million TRY turnover threshold remains in effect for the e-Invoice obligation in 2026, and businesses within this scope are also required to implement the e-Ledger system simultaneously.

When Will the e-Invoice and e-Archive Requirement Start for Auto Galleries?

Businesses that are required to adopt the e-Invoice system or choose to transition voluntarily must also use the e-Archive Invoice system. Therefore, companies can switch to the e-Archive application at the same time they apply for e-Invoice.

The main details in the communiqué are as follows:

e-Commerce intermediary service providers, companies that publish online listings, and businesses providing digital advertising services must switch to the e-Archive Invoice system within 3 months of starting their activities.
With the new regulations, the monetary threshold previously applied to invoices issued to non-taxpayers has been removed.
As of January 1, 2026, all sales made to non-taxpayers must be documented with an e-Archive invoice regardless of the amount. Therefore, the 3,000 TRY limit applied in previous years is no longer valid.
For taxpayer customers, the general invoice issuance threshold applies. In 2026, the invoice issuance requirement is set at 12,000 TRY.

For sales made to the same person on the same day:

Up to 12,000 TRY, a cash register receipt (ÖKC receipt) may be issued.
If the total amount exceeds 12,000 TRY, a receipt can no longer be issued for that amount, and the transaction must be documented with an e-Invoice or e-Archive Invoice, depending on the taxpayer status of the buyer.

As an exception, taxpayers who are taxed under the simplified method or keep books based on the operating account method may issue paper invoices for transactions up to 3,000 TRY until December 31, 2026. Transactions exceeding this amount must be documented with an e-Archive invoice.

The Concept of Internet Sales for Auto Gallery Businesses

When evaluating invoicing obligations for auto gallery businesses, the concepts of “internet sales” and “sales intermediation” mentioned in the communiqué should be examined.

According to the regulation, internet sales are defined as sales where the entire ordering and purchasing process of goods or services is completed online.

Based on this definition, if your business model includes:

receiving orders through the internet,
creating rental or service contracts electronically,
completing the entire sales process in digital environments,

your business may be required to transition to the e-Invoice and e-Archive systems.

For this reason, it is recommended that companies consult their financial advisors or accountants to clearly determine their obligations.

How to Apply for e-Invoice?

The first step in transitioning to the e-Invoice system is obtaining a financial seal (mali mühür). After acquiring the financial seal, the application can be submitted through the online e-Invoice application system of the Turkish Revenue Administration.

When Can an e-Invoice Application Be Made?

Businesses can apply for the e-Invoice system at any time voluntarily. However, taxpayers who fall under the mandatory scope were required to complete their applications and transition to the system by July 1, 2025.

How to Check an e-Invoice Application?

The e-Invoice application status can be checked through the live e-Invoice inquiry system using a tax identification number or Turkish ID number. The information displayed on the screen should be compared with existing records for verification.

Special VAT Base in Car Rental and Vehicle Trading

The special VAT base system is particularly relevant for businesses engaged in second-hand motor vehicle trading. Under this system, if the seller purchases a vehicle from a non-VAT taxpayer or from a taxpayer within an exemption scope and then sells it to another buyer, VAT is calculated only on the profit margin.

In other words:

Selling price – purchase price = special VAT base (profit)
VAT is calculated only on this difference.

However, if the vehicle was purchased with VAT, the special VAT base system cannot be applied during the sale.

For the special base system to be applicable:

the vehicle must not undergo fundamental modifications,
only minor repairs, maintenance, or simple modifications should be performed,
the seller must possess a valid authorization certificate.

For example:

maintenance work or changing the wheels does not count as a fundamental modification,
replacing the engine or major components is considered a fundamental modification.

This allows the invoice to be officially issued electronically under the special VAT base scheme.

e-Invoice Programs for Car Rental and Auto Trading Businesses

In the car rental and second-hand vehicle trading sector, many details must be tracked carefully. Information such as:

the time the vehicle is rented and returned,
maintenance schedules,
usage period and vehicle condition,
damage records,
invoicing processes

must all be recorded accurately.