What Is Tax Legislation?
What Is Tax Legislation?
Tax legislation refers to the legal regulations related to the state’s financial activities carried out to fund public expenditures. Within the scope of the Tax Procedure Law, changes have been made regarding the use of e-documents, and new regulations have been published by the Revenue Administration (GİB) as a draft communiqué.
In the new GİB draft communiqué, mandatory transition requirements for e-Invoice and e-Ledger applications have been announced. We recommend noting the dates below and emphasize the importance of not missing them.
Taxpayers who meet the conditions for mandatory transition to e-Invoice and e-Archive Invoice as stated in the communiqué published by the Revenue Administration completed their transition to these systems by 1 July 2025.
According to the gross sales revenue (or gross business income) criteria determined for 2025, taxpayers transitioned to the e-Invoice system by 1 July 2025.
Now, let’s take a closer look at the details of these regulations.
Regulations on Electronic Transactions
In order to expand the use of e-Transformation applications, mandatory transition requirements for e-Invoice, e-Archive Invoice, and e-Dispatch Note are revised every year. As a result, turnover thresholds have been gradually reduced compared to previous years.
Mandatory e-Invoice, e-Archive, and e-Ledger Applications
Taxpayers whose gross sales revenue (or gross business income) for 2022 and subsequent accounting periods (2023, 2024, and 2025) is 3 million TRY or more are required to transition to e-Invoice, e-Archive Invoice, and e-Ledger applications.
Although the mandatory transition date for e-Invoice and e-Archive in 2026 has not yet been announced, in previous years this date generally fell on 1 July.
If your company’s gross sales revenue exceeds 3 million TRY for 2022 and subsequent periods, transitioning to the e-Invoice system is mandatory.
Previously, if taxpayers had voluntarily transitioned to e-Invoice and e-Archive Invoice systems and did not exceed the specified limits, they were not required to use the e-Ledger application. However, under the new regulation, all taxpayers keeping books on a balance sheet basis are required to keep e-Ledgers, regardless of their e-Invoice status.
In addition, as of 2026, all invoices issued by taxpayers who are not e-Invoice users must be issued as e-Archive Invoices, regardless of the invoice amount.
Mandatory e-Archive Use for e-Invoice Users
Some companies had transitioned to e-Invoice but not to e-Archive Invoice. Under the new regulation, these companies are now required to use the e-Archive Invoice system and can no longer issue paper invoices.
Mandatory e-Ledger Application
According to the announcement regarding taxpayers required to use the e-Ledger application, the following statements are included:
Taxpayers required to transition to the e-Invoice application must switch to the e-Ledger application within the transition period. Companies subject to independent audit under Article 397 of the Turkish Commercial Code are required to transition to the e-Ledger system as of 1 January 2021, while those meeting the audit requirements in subsequent years must transition starting from the beginning of the following year.
Mandatory Transition to e-Invoice Under Communiqué No. 509
According to Communiqué No. 509 of the Tax Procedure Law, taxpayers required to transition to the e-Invoice application include:
• Taxpayers with gross sales revenue of:
o 5 million TRY for 2018, 2019, or 2020
o 4 million TRY for 2021
o 3 million TRY for 2022 and subsequent periods
• Taxpayers licensed by the Energy Market Regulatory Authority (EPDK) due to activities involving goods listed in Schedule I of the Special Consumption Tax Law
• Taxpayers manufacturing or importing goods listed in Schedule III of the Special Consumption Tax Law
• E-commerce intermediary service providers and online sellers exceeding specified turnover limits
• Fruit and vegetable traders and commission agents
• Healthcare service providers contracted with the Social Security Institution (SGK)
• Taxpayers engaged in real estate or motor vehicle trading, rental, or brokerage activities exceeding the specified turnover limits
Invoice Issuance Limits
For 2025, the invoice issuance limits determined by GİB are as follows:
• 9,900 TRY (including taxes) for invoices issued to taxpayers
• 3,000 TRY (including taxes) for invoices issued to non-taxpayers
All invoices exceeding these limits must be issued electronically. As of 2026, the 3,000 TRY limit will be completely removed.
Mandatory e-Dispatch Note (e-İrsaliye)
According to the communiqué, companies with 2021 turnover exceeding 10 million TRY transitioned to the e-Dispatch Note system as of 1 July 2025. The transition date for 2026 has not yet been finalized.
e-Ledger Submission Periods
Under the new regulations, e-Ledger submission files may be sent monthly or quarterly, at the taxpayer’s discretion.
Use of e-Producer Receipts
If your company purchases agricultural products and issues producer receipts and is an e-Invoice taxpayer, you must use e-Producer Receipts as of 1 July 2022. Companies that are not e-Invoice taxpayers may continue issuing producer receipts in paper form.
What Is an Electronic Warehouse Receipt (ELÜS)?
An Electronic Warehouse Receipt (ELÜS) is a digital document used in the trading of agricultural products. It represents ownership of products stored in licensed warehouses and enables a secure and transparent trading system.
How to Query ELÜS
ELÜS queries can be made through:
• Central Registry Agency (MKK)
• Turkish Mercantile Exchange (TÜRİB)
• e-Government (e-Devlet)
These platforms allow users to check product details, ownership information, and transaction records.
