Additional Time for Ymms for E-Official Records
Official titleAmendment to the Communiqué (Serial No: 2) on the Electronic Submission of Counter-Review Official Records Added to Sworn-In Certified Public Accountant Certification Reports (Serial No: 1)
The start date of the requirement for the counter-review official records added by sworn-in certified public accountants (YMMs) to their certification reports to be submitted electronically has been postponed from 1 July 2026 to 1 January 2027.
Before
The start date of the requirement to submit counter-review official records electronically had been set as 1 July 2026.
After
The start date for mandatory electronic submission has been changed to 1 January 2027.
Details of the Regulation
Through this Communiqué published by the Revenue Administration Presidency of the Ministry of Treasury and Finance, a substantial extension has been granted regarding the requirement for the counter-review official records that sworn-in certified public accountants are obliged to include in the certification reports they prepare to be submitted electronically. With the amendment made, the start date for electronic submission, previously set as 1 July 2026, has been postponed by 6 months and revised to 1 January 2027.
The relevant regulation directly affects the effective date in the second paragraph of Article 7 of Communiqué No: 1, published in the Official Gazette dated 24 December 2025 and numbered 33117. This postponement decision was taken to ensure that the technical infrastructure of the implementation operates without problems and that the relevant stakeholders can better adapt to the transition process.
Although the new Communiqué entered into force on its publication date, 21 August 2026, it was drafted to apply retroactively as of 1 July 2026. This is intended to prevent legal gaps and situations giving rise to criminal liability from arising during the period between 1 July 2026 and the date on which the Communiqué was published.
Questions You Might Have
- How will this postponement decision affect sworn-in certified public accountants?
- YMMs will be able to continue preparing and submitting counter-review official records in physical form for some time and will have gained an additional 6 months for integration into the new digital system.
- Why is the Communiqué, although published in August, deemed to have been valid as of July?
- The effective date has been arranged retroactively so that no administrative or criminal dispute will arise because the requirement, which was supposed to commence on 1 July 2026, was not actually implemented as of that date.
Key Terms
- Tasdik Raporu
- The official document certifying that sworn-in certified public accountants have confirmed that taxpayers’ returns and accounts comply with the legislation.
- Karşıt İnceleme
- The confirmation of accuracy carried out before other taxpayers with whom taxpayers engage in the purchase and sale of goods and services.
- Yürürlük Tarihi
- The date on which a statute, regulation, or communiqué enters into force and acquires legal validity.
Affected Sectors
- Financial advisory and consultancy services
- Accounting services
- Taxpayer companies
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REGAS Commentary
This postponement is a highly reassuring development for sworn-in certified public accountants and the taxpayers working with them. Practitioners who have not been able to fully adapt to the electronic system have gained an additional critical 6 months to digitalize and test their business processes.