Turkey: Electronic Invoicing and Electronic Ledger Thresholds in 2026

From January 1, 2026, most Turkish taxpayers outside the registered electronic invoicing systems must issue invoices electronically, regardless of value. Existing turnover thresholds also determine when businesses must join the electronic invoicing system, affecting retailers, e-commerce businesses and software providers.

Turkey has expanded its electronic invoicing requirements from January 1, 2026, removing the minimum invoice value for most taxpayers using the Tax Authority’s electronic archive invoice portal.

The change forms part of an existing regulatory framework rather than introducing an entirely new electronic invoicing system. Alongside the new invoice issuance rules, businesses must continue monitoring turnover thresholds that determine when registration in the electronic invoicing system becomes mandatory.

For retailers and businesses operating through several sales channels, understanding these requirements is necessary to ensure that invoices are issued in the correct electronic format.

Under Tax Procedure Law General Communiqué No. 509, amended by Communiqué No. 535, businesses generally become subject to mandatory electronic invoicing when their annual gross sales revenue reaches TRY 3 million (~EUR 54.135).

The threshold has applied since the 2022 accounting period and has not been adjusted annually for inflation.

For businesses using a calendar-year accounting period, registration becomes mandatory on July 1 of the year following the period in which the threshold was reached.

Certain sectors are subject to lower thresholds or special registration requirements.

These include businesses involved in real estate and motor vehicle transactions, online marketplaces, internet advertising activities and other specifically regulated sectors.

For some categories, the relevant threshold is TRY 500,000 (~EUR 9,000), while other activities trigger registration regardless of turnover. Sector-specific commencement rules must therefore be checked separately.

One of the main changes introduced for 2026 concerns businesses that are not registered in either the electronic invoicing or electronic archive invoicing system.

Previously, such businesses could issue paper invoices below the applicable value threshold.

From January 1, 2026, however, invoices that these taxpayers are required to issue must generally be created electronically through the Tax Authority’s electronic archive invoice portal, regardless of their value.

An exception applies to taxpayers under the simplified taxation method and those maintaining business-account books. For these categories, the TRY 3,000 (~EUR 54) threshold continues until December 31, 2026. From January 1, 2027, the value restriction will also disappear for them.

The transitional arrangement was introduced through Tax Procedure Law General Communiqué No. 589, published on December 31, 2025.

Businesses registered in the electronic invoicing system must continue distinguishing between customers who are registered and those who are not.

An electronic invoice is used for transactions between registered taxpayers, while an electronic archive invoice is generally issued to customers outside the registered electronic invoicing system.

Importantly, the removal of the electronic archive invoice value threshold does not mean that every retail transaction automatically requires an invoice.

A separate rule under Article 232 of the Tax Procedure Law determines when an invoice must be issued. For 2026, the relevant invoice issuance threshold is TRY 12,000 (~EUR 2,160), subject to the applicable rules and customer requests.

This distinction remains particularly relevant for retailers issuing ordinary retail sales receipts through cash registers.

Electronic ledger obligations are regulated separately under Electronic Ledger General Communiqué No. 1 and its amendments.

The system applies to businesses required to register for electronic invoicing, companies subject to independent audit and taxpayers maintaining accounts under the balance-sheet method.

The last category became mandatory from January 1, 2025, following Communiqué No. 5.

Consequently, a business may already be required to maintain electronic ledgers even if it has not reached the general electronic invoicing turnover threshold.

For businesses entering electronic invoicing during the year solely because they meet the applicable registration criteria, the electronic ledger obligation generally begins at the start of the following year, unless another rule requires earlier adoption.

Electronic ledger files and their approval files must be prepared and submitted according to the applicable schedule.

Under the general monthly rules, the deadline is the 10th day of the fourth following month for personal income taxpayers and the 14th day for other taxpayers. Different rules apply to the final accounting period and quarterly submission arrangements.

Businesses should also consider official deadline extensions.

Turkey's electronic document framework also covers electronic delivery notes and electronic self-employment receipts.

Electronic delivery notes are mandatory for registered electronic invoicing users reaching the TRY 10 million (~EUR 180,450) turnover threshold, based on accounting periods from 2021 onward, as well as certain regulated activities regardless of turnover.

These requirements are particularly relevant for retailers, wholesalers and distributors transporting goods between warehouses, stores and customers.

Electronic self-employment receipts are mandatory for taxable self-employed professionals, independently of the general electronic invoicing turnover threshold.

Impact on affected businesses

For retailers, the practical consequence is the need to distinguish between electronic invoices, electronic archive invoices and ordinary retail sales receipts.

Businesses operating physical stores, online shops and business-to-business sales channels should verify whether their invoicing software selects the appropriate document according to the customer's registration status and the applicable transaction rules.

POS software providers and ERP integrators should assess whether their solutions support the required electronic documents and communication with the Revenue Administration or authorized service providers.

Electronic delivery notes may also require coordination between warehouse management, order processing and invoicing systems.

However, these invoicing developments do not automatically replace existing cash register or fiscal receipt requirements. Any exemption from cash register use must be assessed separately.

What should businesses do?

Affected businesses should review their annual gross sales revenue, confirm whether sector-specific registration requirements apply and establish the correct implementation deadlines.

Retailers should verify invoice selection across sales channels and ensure that POS and ERP solutions correctly distinguish electronic invoices, electronic archive invoices and retail sales receipts.

Businesses should also review electronic ledger obligations independently of their electronic invoicing status and confirm the applicable submission deadlines.

The most relevant issue is the combination of fixed turnover thresholds and the broader requirement to issue invoices electronically.

As the general TRY 3 million threshold remains unchanged, businesses can become subject to mandatory electronic invoicing without substantial growth in their actual business activity.

For international retailers, this makes regular monitoring of Turkish subsidiaries' local turnover particularly important.

The main source for this article is the CPA4Turkey.com article regarding the e-Invoice and e-Ledger thresholds in Turkey. Source

Ivana Picajkić, Medior Legal Consultant at Fiscal Solutions

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