Foreign groups that open a Turkish company arrive with an invoicing habit from home, and the first Turkish invoice they issue is often the first mistake I am asked to repair. Turkey has moved most business documents onto the Revenue Administration's electronic systems: the invoice between registered users is an e-Fatura that travels through the Administration's servers, the invoice to anyone else is an e-Arşiv Fatura issued and reported through the same infrastructure, the delivery note and the professional receipt have electronic forms of their own, and the ledgers are kept as e-Defter with periodic certificates uploaded to the Administration. The rules sit in one long communiqué under the Tax Procedure Law, amended almost every year, and the thresholds that trigger them are low enough that a subsidiary of modest size crosses them in its first or second year. This page sets out who is caught, from when, how a company controlled from abroad joins the system and signs, where the files must live, and what happens when an invoice that should have been electronic is issued on paper.
Sources, checked 9 September 2026. Tax Procedure Law No. 213, Articles 232 and 353; Tax Procedure Law General Communiqué No. 509 (Official Gazette 30923, 19 October 2019) in the Revenue Administration's consolidated 2026 text, including Communiqués Nos. 535, 550, 573 and 589; Electronic Ledger General Communiqué No. 1 (Official Gazette 28141, 13 December 2011) as amended by Communiqués Nos. 3 (Official Gazette 30923, 19 October 2019) and 6 (Official Gazette 32769, 31 December 2024); Tax Procedure Law General Communiqué No. 588 (Official Gazette 33124 (5th repeat), 31 December 2025) for the 2026 amounts.
The documents, and the one word that defines them
Communiqué No. 509 treats each electronic document as having the same legal character as its paper predecessor, so an e-Fatura is an invoice under the Tax Procedure Law, with the same content requirements, the same retention duty and the same penalties. The difference is who may issue what to whom. An e-Fatura can be exchanged only between users registered in the Administration's e-Fatura system, whose current list is published on the Administration's e-document site; an invoice from a registered user to a customer who is not registered, including a private individual, a foreign customer or a small Turkish business below the thresholds, is issued as an e-Arşiv Fatura, created electronically, delivered to the customer electronically or on paper, and reported to the Administration. A registered user therefore issues both, and the first check in any Turkish invoicing workflow is whether the counterparty is on the registered list on the date of the invoice.
Who must use e-Fatura, and from when
Section IV.1.4 lists the taxpayers who must join. The general trigger is gross sales revenue of 3 million TL or more in the 2022 accounting period or any later period, and the transition under section IV.1.5 is the start of the seventh month of the year following the period in which the threshold was met, so a company whose 2025 turnover reached the figure must be issuing e-Fatura from 1 July 2026. The sector triggers do not wait for turnover: holders of an Energy Market Regulatory Authority licence for the petroleum products in list I of the Special Consumption Tax Law, and producers, builders and importers of the list III goods, alcohol and tobacco among them, within the fourth month after the licence or the first production or import; intermediary service providers, online classified sites for property and vehicles, internet advertising intermediaries and any business selling goods or services through its own or a marketplace's website with gross sales of 500,000 TL or more from 2022, by the seventh month of the following year; fruit and vegetable traders and commission agents; health service providers and medical suppliers contracted to the Social Security Institution, before their first invoice to it; businesses that build, produce, buy, sell or lease real estate or motor vehicles, or broker those transactions, with gross sales of 500,000 TL or more from 2022; hotels holding a tourism investment or operating licence from the Ministry or a municipality; and licensed electric vehicle charging network operators and the stations they certify. Three corporate events carry the obligation across: a merger, full division or change of legal form obliges the surviving or new entity to join within three months of the month following registration, a sole trader who was or should have been a user and converts to a company brings the company in on the same timetable, and a person who leaves the system on ceasing business and later re-registers rejoins on the day of restarting. Anyone below the thresholds may join voluntarily, and public bodies join through the Ministry's integrated public financial management system.
e-Arşiv: the rule that now reaches every business
Section IV.2.4.1 requires every taxpayer that is in the e-Fatura system, by obligation or by choice, to join the e-Arşiv system within the same period, so that from its transition date every invoice it issues is either an e-Fatura or an e-Arşiv Fatura. Section IV.2.4.3 then reaches the businesses that are in neither system. During 2025 an invoice issued by a non-user whose total including taxes exceeded 3,000 TL had to be issued as an e-Arşiv Fatura through the Administration's e-document portal; from 1 January 2026 the amount test disappears for balance-sheet taxpayers and every invoice they issue must be an e-Arşiv Fatura issued through the portal or through an integrator. Communiqué No. 589, published on 31 December 2025, kept the 3,000 TL test in place for taxpayers taxed on the simple basis or keeping operating-account books until 31 December 2026, with the amount-free rule applying to them from 1 January 2027. The practical consequence for a foreign-owned company is that the paper invoice book has no remaining role once the company keeps balance-sheet books, which every limited and joint stock company does.
The other electronic documents
Section IV.3.5 makes the electronic delivery note, e-İrsaliye, mandatory for e-Fatura users whose gross sales reached 10 million TL in 2021 or a later period, from the seventh month of the following period, and for listed sectors regardless of turnover: the petroleum and alcohol and tobacco groups above, mining licence holders and their contracted producers, sugar producers, producers, importers and exporters of iron and steel and articles of them, users registered in the fertiliser tracking system, fruit and vegetable traders, and businesses in the construction steel tracking system with gross sales of 1 million TL or more from 2024; the Administration may also bring in taxpayers it identifies as risky. Section IV.4.4 makes the electronic receipt mandatory for every professional who is not tax-exempt. Section IV.1.7.1 requires e-Fatura users to issue their export invoices under Article 11 of the VAT Law, and invoices for goods carried out by travellers, as e-Fatura routed through the customs administration, a rule in force since 1 July 2017 and one that ties the invoicing system to the export procedure described on the import and customs page.
e-Defter: the ledgers follow the invoices
The Electronic Ledger General Communiqué requires two groups to keep the journal and the general ledger as e-Defter: taxpayers who are obliged to use e-Fatura, and companies subject to independent audit under Article 397(4) of the Commercial Code. An e-Fatura user must start e-Defter within its e-Fatura transition period, or, where it joined e-Fatura during a year, from the start of the following year. Since Communiqué No. 6 of 31 December 2024 the commercial enterprises of associations and foundations that keep balance-sheet books are also within the obligation, the inventory ledger may be kept electronically by choice unless the Administration prescribes it, and the certificates and ledger files are uploaded on a fixed calendar: the opening certificate by the tenth day of the fourth month for income tax payers and the fourteenth for others, and the closing certificate by the tenth or fourteenth day of the month following the month of the annual return. A Turkish subsidiary that crosses the 3 million TL line therefore inherits three obligations in sequence: e-Fatura and e-Arşiv on the following 1 July, and e-Defter from the following 1 January.
Joining, signing and storing: the points a foreign group must plan
Section V.1 gives three ways to use the systems. The Administration's own portal is designed for users without integrated systems and offers the basic functions through a web interface. A private integrator licensed by the Administration issues and receives documents on the taxpayer's behalf and may, at the taxpayer's request, sign them with its own seal and timestamp. Direct integration connects the taxpayer's own systems to the Administration's, and the communiqué expressly contemplates taxpayers whose information systems are managed from abroad, who may be permitted to integrate on application; a group that runs its Turkish company on a global system should apply on that footing rather than assume that a foreign server disqualifies it. Signing is by the financial seal, the Mali Mühür, an electronic certificate issued on the Administration's behalf by TÜBİTAK, which legal persons must use and natural persons may replace with a qualified electronic signature; the seal is tied to the company's registered title, a change of title invalidates it and a new certificate must be applied for within fifteen days, and the persons authorised to use it must be notified to the Administration and updated when they change. Storage is the rule most often broken by foreign groups: the communiqué requires the taxpayer's own information systems and the documents kept on them to be located within the borders of Turkey and in places where Turkish law applies, and a secondary archive abroad is permitted only in addition to that. Documents are kept in electronic form with the seal or signature intact for the statutory retention period, and a printout does not satisfy the duty; a third party may store them only with the Administration's storage licence.
What a paper invoice now costs
Article 232 of the Tax Procedure Law requires an invoice for sales to traders, professionals and other invoice-issuing persons, and to anyone else where the price exceeds 12,000 TL for 2026 or the customer asks; below that figure a retail receipt suffices. Article 353(1), as amended in 2018 and 2024, treats the issue of a document on paper where an electronic form was mandatory in the same way as not issuing it at all: a special irregularity penalty of ten per cent of the amount that should have appeared on the document, and in 2026 not less than 17,000 TL per document on a first finding in a calendar year, with higher minimums on later findings, imposed on the issuer and on the recipient alike, and calculated document by document even where several are found in one inspection. Section IV.1.6 of Communiqué No. 509 applies the same penalties to a taxpayer that fails to join the system on time. Because the penalty attaches to each invoice, a subsidiary that missed a 1 July transition and kept invoicing on paper for a quarter faces a number that grows with every sale; the exposure is on the company and, through the tax office's usual routes, on its managers.
How this fits the rest of the company's compliance
The invoicing system is downstream of the choices on the company formation page: a liaison office issues no invoices because it may not trade, a branch and a subsidiary are ordinary taxpayers and join on the same thresholds, as explained on the liaison office, branch and subsidiary page. The bank account that receives the invoiced sums is described on the bank account page, the corporate tax the ledgers feed on the corporate tax page, and the withholding and reverse-charge VAT that arise when the same company pays a foreign supplier on the withholding tax page.
Whose side we are on, and how we are paid
The software vendor sells the integration and does not tell you the threshold you crossed last year. The accountant files what the system produces. The integrator signs what it is sent. None of them is paid to tell you, before 1 July, that your turnover put you in the system, that your title change invalidated the seal, or that your documents are being archived on a server outside Turkey in breach of the communiqué.
We take no commission or referral fee from integrators, software vendors or accountants, in any form, on any file. The fee you pay us is our only income from your matter, and it does not depend on which system or vendor you choose. Because our position does not move with the vendor, telling you that the Administration's own portal is enough for your volume, or that your group system needs an integration permit, costs us nothing to say.
One boundary, stated plainly. We are lawyers, not licensed investment advisers and not your bookkeepers. We do not run your invoicing or keep your ledgers. What we protect is the Turkish legal position: whether and when your company is caught, the corporate events that carry the obligation across, the signing and authorisation of the seal, the storage location, the treatment of exports and foreign customers, and the defence when a penalty notice arrives.
Before the next 1 July
Send us your last two years' turnover, your sector and licences, your group's invoicing and ERP setup and where it is hosted, and any pending merger, conversion or title change. We will tell you which systems you must join and by which date, which access method fits, what the seal and storage rules require of your group, and how to handle invoices to foreign customers and exports. Our corporate compliance work is described on the corporate law page.
What this page does not settle
The technical formats and integration guides, the electronic delivery of documents to customers, the e-Bilet, e-Müstahsil and insurance document systems, the VAT treatment of the invoiced supplies, transfer pricing documentation and the accounting standards behind the ledgers are separate subjects. Thresholds and dates are those in the communiqué text on the date checked; the Administration amends it at least annually.
