General Letter Published Regarding Share Ledger Opening Procedures in the Electronic Commercial Ledger System
With its General Letter No. 1054 dated 05.12.2025 (“General Letter”), Merkezi Kayıt Kuruluşu A.Ş. (“MKK”) has set out the procedures and principles regarding the opening of share ledgers through the Electronic Commercial Ledger System (“ETDS”). The General Letter outlines key points that issuer companies, particularly those whose registered shares are monitored in book-entry form, should take into consideration when completing the closure of physical share ledgers and initiating opening procedures on ETDS.
As is known, all companies whose establishment is to be registered with the trade registry as of 01.01.2026, shall be obligated to maintain their share ledger and general assembly meeting and negotiation book in the ETDS. Furthermore, existing companies whose establishment and amendments to their articles of association are subject to the authorization of the Ministry of Trade shall be required to transition to the ETDS by the same date, namely 01.01.2026. This matter has been reaffirmed in the announcement issued by the Ministry of Trade dated 18.12.2025.
The key points in the General Letter can be summarized as follows:
- For the closure and opening of share ledgers: (i) information regarding the company’s non-listed shares must be provided on a shareholder and shareholding ratio basis; (ii) information regarding the company’s listed shares must indicate only the public float ratio.
- Public companies will be able to obtain a shareholder list from MKK, limited solely to holders of non-listed registered shares. This list will be provided on a one-time basis.
- For the application, relevant companies must have the application form provided by MKK signed by their authorized signatories with unlimited signing authority and submit it to MKK’s KEP address. The service will be subject to a fee of TRY 10,000 + VAT.
- Companies whose shares are entirely bearer shares fall outside the scope and are therefore not required to apply.
You may access the full General Letter from here and the announcement of the Ministry of Trade here.
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