Communiqué Amending the Electronic Commercial Ledger Practice

Significant regulations have been introduced to the scope and implementation principles of commercial ledgers to be kept electronically under the Communiqué on Keeping Commercial Ledgers Not Related to the Accounting of the Enterprise in Electronic Format (Communiqué), published in the Official Gazette dated 14 February 2025 and no. 32813. Under the new communiqué, published in the Official Gazette dated 14 August 2025 and no. 32986 (Amending Communiqué), significant amendments have been made to the Communiqué.

Within the scope of the Amendment Communiqué, the board of directors’ resolution books of banks, asset management companies, as well as financial leasing, factoring, financing and savings financing companies, subject to the supervision and regulation of the Banking Regulation and Supervision Agency, have been excluded from the mandatory electronic ledger requirements.

Accordingly, with the said amendment, only the board of directors’ resolution books of the above-mentioned companies have been removed from the scope of the e-ledger obligation. These companies may continue to keep their board of directors’ resolution books in physical form, as was previously the case. No exemption has been introduced by this Amendment Communiqué regarding their other statutory books (for example, the share ledger, the general assembly meeting book, etc.) or for other publicly held companies.

Furthermore, the regulations introduced for companies operating in the defense industry, as set forth in Article 2 of the Amendment Communiqué, should also be considered.

In summary, this Amendment Communiqué does not currently provide for an exemption applicable to all publicly held companies. The exemption applies only to the board of directors’ resolution books of the companies listed in the first article. We would like to emphasize that publicly held companies should follow closely the relevant e-ledger legislation and any amendments thereto.