The Era of Special Integrators for e-Expense Notes: What Does the New GİB Technical Regulation Change?
The Era of Special Integrators for e-Expense Notes: What Does the New GİB Technical Regulation Change?
The new technical package published by the Turkish Revenue Administration (GİB) enables e-Expense Notes to be prepared and submitted through authorized private integrators. While e-Invoice taxpayers can voluntarily switch to the system without waiting for a mandatory requirement, taxpayers who receive a written notification from GİB must transition to the system within the minimum three-month period granted to them.
In this guide, we examine the scope of the e-Expense Note application, transition options, who can use the system, and how an e-Expense Note can be issued through a private integrator.
e-Expense Note Application at a Glance
- GİB has published the technical regulation allowing private integrators to provide e-Expense Note services.
- Private integrators that complete the required technical and administrative procedures will be able to offer e-Expense Note services to their customers.
- An e-Expense Note is used to electronically document purchases of goods and services from individuals who are unable to issue invoices.
- Businesses wishing to voluntarily adopt the system must be registered for the e-Invoice application, complete the necessary technical preparations, and submit an application.
- GİB may require certain taxpayers to switch to the system within at least three months by sending them a written notification.
- e-Expense Notes can be issued through the GİB Portal, direct integration, or an authorized private integrator.
New Regulation from GİB: Private Integrators Can Now Offer e-Expense Note Services
On May 22, 2026, the Turkish Revenue Administration published the e-Expense Note technical package and guide on ebelge.gib.gov.tr. Under the new regulation, e-Invoice taxpayers can prepare their e-Expense Notes through private integrators authorized by GİB and submit them to the GİB system.
This structure is similar to the private integrator model that has been used for e-Invoices and e-Archive Invoices for many years.
According to the published technical regulation, e-Expense Notes must be generated in accordance with the UBL 2.1 standard and the electronic profile specified by GİB. The document must be electronically signed using a financial seal or a qualified electronic signature in compliance with the XAdES-BES standard.
In simple terms, this regulation means that expense notes are also moving from paper-based processes to a fully digital document structure, similar to invoices and e-Archive Invoices. XAdES-BES is an international electronic signature standard that ensures the electronic signature is securely transmitted together with the document while maintaining its integrity.
If the accounting software or private integrator used by the business already supports these technical standards, users do not need to deal with the technical details themselves.
The most important issue for businesses is making sure that the transition requirement is not overlooked. Following GİB's announcement, many accounting software providers and private integrators accelerated their efforts to make their infrastructure compatible with the new system. For this reason, businesses that are either subject to the mandatory transition or considering voluntary adoption should plan the process in advance to avoid potential technical and operational problems.
This development officially opens the way for private integrators to facilitate the transition from paper-based expense notes to electronic processes. It is particularly relevant for businesses making payments to influencers or content creators, companies purchasing goods or services from individuals benefiting from the tradesperson exemption, and retail businesses.
In this article, we explain step by step what an e-Expense Note is, who it applies to, which methods can be used to issue it, and how businesses can transition through a private integrator.
What Is an e-Expense Note?
An expense note is an official document issued by businesses to document purchases of goods and services from individuals who are not taxpayers or who are unable to issue invoices.
Individuals benefiting from the tradesperson exemption, people providing occasional services, and individuals selling second-hand goods may fall within this scope. Unlike an invoice, an expense note is issued by the purchasing business rather than the person selling the goods or services.
An e-Expense Note is the electronic version of the traditional expense note. It is prepared in accordance with the technical standards established by GİB, electronically signed, and submitted through the relevant system.
Key Differences Between Paper Expense Notes and e-Expense Notes
An e-Expense Note has the same legal function as a paper expense note, but it is prepared electronically and approved using a financial seal or qualified electronic signature.
Therefore, the main difference between the two documents is not their legal validity but how they are created, approved, transmitted, and stored.
Paper Expense Note vs. e-Expense Note
| Criteria | Paper Expense Note | e-Expense Note |
|---|---|---|
| Preparation method | Physical document and handwritten signature | Electronic environment and financial seal/QES |
| Document format | Printed or free-form document | UBL 2.1-based electronic format |
| Transmission | Delivered in person or by mail | Electronically transmitted to the GİB system |
| Archiving | Physical storage, 5 years | Digital storage through the private integrator or GİB systems |
| Accounting processes | Manual data entry | Automatic and real-time accounting integration |
| Legal validity | Valid | Legally equivalent to the paper document |
Who Will Use e-Expense Notes and When Will the Transition Take Place?
It is important to distinguish between two different situations. There is currently no general e-Expense Note obligation covering all businesses. However, certain businesses are subject to mandatory use if they meet specific conditions.
Businesses Subject to the Mandatory Requirement
As of January 1, 2026, certain businesses are required to use e-Expense Notes under the regulation introduced through Communiqué No. 573 to Communiqué No. 509 of the Tax Procedure Law.
The obligation applies when all of the following conditions are met:
- The business has an NACE code beginning with 47 among its activity codes, indicating retail activity.
- The business is registered for the e-Invoice application.
- At the end of the 2024 accounting period, the business meets at least two of the following three financial criteria:
- Sales or gross business revenue exceeding TRY 110 million,
- Total balance sheet assets exceeding TRY 110 million,
- Total equity or shareholders' equity exceeding TRY 11 million.
- These financial thresholds are updated annually according to the revaluation rate announced under repeated Article 298 of the Tax Procedure Law. Fractions below five percent are disregarded in the calculation.
To illustrate this with a practical example, consider a chain store whose NACE code begins with 47 and which is an e-Invoice taxpayer. If its 2024 sales revenue exceeds TRY 110 million and its total balance sheet assets also exceed the specified threshold, it meets at least two of the required financial criteria. In this case, the business is required to use e-Expense Notes.
By contrast, a service business with the same financial size but operating under a different NACE code may not currently fall under this mandatory requirement.
Therefore, businesses should assess both their NACE codes and their 2024 financial statements when determining whether they are subject to the requirement.
Voluntary Transition
Businesses outside the mandatory scope are not currently subject to a general e-Expense Note requirement.
However, e-Invoice taxpayers can voluntarily transition to the e-Expense Note system without waiting for a mandatory obligation. For businesses seeking to digitize their processes early, this can provide operational advantages.
Taxpayers Notified by GİB
GİB may also require certain taxpayers to transition to e-Expense Notes based on its analyses and audit activities, particularly where taxpayers are considered high-risk or have a low level of tax compliance.
In such cases, the taxpayer receives a written notification and is granted a minimum three-month period for the transition.
For this reason, businesses that are currently outside the mandatory scope should still monitor legislative changes and any notifications issued by GİB.
Comparing e-Expense Note Transition Methods
| Method | Best Suited For | Advantages | Disadvantages |
|---|---|---|---|
| GİB Portal | Small businesses issuing a limited number of documents | No additional software or installation costs | Manual processes, no accounting integration, inefficient at high volumes |
| Direct Integration | Large companies with strong technical infrastructure and high transaction volumes | May provide long-term cost advantages | Requires technical expertise and continuous monitoring of legislation |
| Private Integrator | Medium and large businesses and companies using accounting software | Automation, integration, reporting, archiving, and regulatory support | Service fees and reliance on the integrator |
GİB Portal
The GİB Portal can be a convenient starting point for businesses issuing only a small number of expense notes. Documents are prepared manually after logging into the portal.
However, as the number of documents increases, entering each transaction individually can create a significant workload. Although avoiding additional software investment may be attractive for small businesses issuing only a few documents per month, manual processing can quickly become time-consuming during busy periods.
Direct Integration
The direct integration method connects the business's own information technology infrastructure directly to the GİB system. It may be particularly suitable for large organizations with high transaction volumes and strong technical teams.
Although it can provide long-term cost advantages, the need for technical infrastructure, specialized personnel, and continuous monitoring of regulatory changes makes this option unsuitable for many businesses.
Using a Private Integrator
The private integrator method offers a practical solution, particularly for medium and large-sized businesses.
Because it can work together with accounting software, it allows documents to be generated automatically. In addition to managing large numbers of transactions, private integrators may also provide additional services such as reporting and electronic archiving.
For many businesses, private integration therefore represents a balanced alternative between the manual workload of the GİB Portal and the technical requirements of direct integration.
Important Points to Consider
- There is currently no general e-Expense Note obligation covering all businesses as of January 1, 2026.
- GİB may notify selected taxpayers in writing and require them to transition to the system within at least three months.
- Businesses wishing to transition voluntarily must be registered for e-Invoices, complete the required technical preparations, and submit the necessary application.
- Not every private integrator can automatically provide e-Expense Note services. The required technical infrastructure and authorization procedures must first be completed.
- Under the general procedure, at least one copy of the e-Expense Note is printed and signed by the recipient. Electronic verification methods may be used in situations specified by GİB.
How Is an e-Expense Note Issued Through a Private Integrator?
Businesses that want to transition to the e-Expense Note system through a private integrator generally need to complete the following steps:
1. Check Taxpayer Status
Since the e-Expense Note system operates in connection with the e-Invoice infrastructure, the business must be an e-Invoice taxpayer before applying.
If the business has not yet transitioned to e-Invoices, this process must be completed first. Therefore, e-Invoice registration is the first requirement that should be checked when planning the transition to e-Expense Notes.
2. Submit the Application
The application can be submitted through GİB's website or through the selected private integrator.
During the application process, the business's taxpayer and contact information must be provided.
3. Obtain a Financial Seal or Qualified Electronic Signature
Legal entities use a financial seal, while natural persons operating as sole proprietorships use a qualified electronic signature.
The required electronic signing tool must be obtained in order for the electronic document to be issued validly. Financial seals can be obtained through authorized suppliers or relevant official channels.
Since this stage can take time, businesses are advised not to leave the application until the last minute.
4. Complete Technical Testing
Following the application, the business's technical infrastructure is checked and test documents are generated.
The private integrator generally provides technical assistance during this stage and verifies that the integration between the systems is functioning correctly.
5. Start Using the System After Approval
Once the necessary approvals have been obtained from GİB, the business can begin issuing e-Expense Notes.
Document types can be configured according to the business's sales, return, and other operational requirements.
When issuing the first documents, carefully checking the document details, party information, transaction description, and amounts helps reduce the risk of incorrect documents.
From a technical perspective, documents are generated in a UBL 2.1-based standard format and electronically signed using a financial seal or qualified electronic signature.
For businesses, however, the key point is that their accounting software or private integrator must support the relevant technical standards. Having this support significantly reduces the need for the business to deal with technical procedures manually.
When Can e-Expense Notes Be Useful?
The practical use of the application can be illustrated through two common examples.
Example 1: Payment to a Content Creator
Consider an e-commerce company working with a content creator for a one-time product promotion.
If the content creator cannot issue an invoice—for example, because they are covered by the tradesperson exemption or are not a taxpayer—the business must issue an expense note to document the payment.
With an e-Expense Note, the transaction can be completed electronically. Processes such as preparing the document and calculating withholding tax can also be automated.
This eliminates the need for the marketing team to spend additional time preparing paper documents and manually tracking paperwork.
Example 2: E-Commerce Returns and Second-Hand Purchases
Consider a retail business purchasing a second-hand product from an individual who is not a taxpayer, or processing a return involving a non-taxpayer.
In such cases, the required expense note can be created quickly and systematically through a private integrator using the relevant sales or return document type.
Especially in stores and return centers with high transaction volumes, using an electronic system can provide significant time savings compared with paper-based processes.
Businesses that previously had to prepare and archive a separate physical document for every transaction can particularly benefit from the automation offered by private integrators in these types of processes.
Transition Period and Potential Penalties
For businesses subject to the mandatory requirement, completing the transition to e-Expense Notes on time is particularly important.
In addition to businesses already covered by the 2026 requirements, taxpayers identified by GİB through risk analysis are also granted a minimum three-month period to transition to the system.
During this period, the application must be submitted, the financial seal or qualified electronic signature must be obtained, and the required integration procedures must be completed.
Taxpayers who fail to transition within the specified period and continue issuing paper expense notes may face penalties under the special irregularity provisions of the Tax Procedure Law concerning document issuance.
Following the amendments made to Communiqué No. 509 through Communiqué No. 573, the legislation continues to evolve. Therefore, e-Expense Notes should not be treated as a matter that can simply be checked once and forgotten.
The general approach of certified public accountants is also consistent with this view. Even businesses outside the mandatory scope should closely monitor legislative changes and notifications that may be issued by GİB if they are e-Invoice taxpayers.
GİB's ability to expand the requirement to additional taxpayers based on risk analysis means that the scope of the application may grow over time.
For this reason, retail businesses with NACE codes beginning with 47 and e-Invoice taxpayers should review their current status together with their certified public accountants and complete the necessary preparations without delay.
In particular, delays in obtaining a financial seal can consume a significant portion of the three-month transition period. Businesses are therefore advised to begin their application and preparation processes as early as possible.
