e-Invoice, e-Archive and e-Ledger Guide Turkey

A limited liability company (limited şirket) or joint stock company (anonim şirket) incorporated in Türkiye in 2026 is not automatically moved to e-Invoice (e-Fatura) on formation. It must, however, issue all of its invoices as e-Archive Invoices (e-Arşiv Fatura), with no amount threshold, and keep its statutory books as electronic ledgers (e-Defter) from the date of incorporation. The e-Invoice obligation generally arises once gross sales revenue in a calendar year reaches 3 million TL, and it starts on 1 July of the following year. In some sectors (for example e-commerce, fuel and hotels) an earlier transition date during the year applies. This guide summarises the scope of the three systems, the transition dates, the methods of use and the penalty amounts for 2026.

The Difference Between the Three Systems

All three systems are based on the Tax Procedure Law (Vergi Usul Kanunu, VUK). The invoice rules are set out in VUK General Communiqué No. 509 (509 Sıra No.lu VUK Genel Tebliği), and the rules on books in the Electronic Ledger General Communiqué (Elektronik Defter Genel Tebliği, No. 1). A general communiqué (genel tebliğ) is secondary regulation issued by the Revenue Administration (Gelir İdaresi Başkanlığı, GİB) to explain how the law is applied.

e-Invoice (e-Fatura): An invoice sent and received electronically through the GİB system, only between two taxpayers that are both registered in the e-Invoice system. Where both the seller and the buyer are registered, all invoices between them are issued as e-Invoices. Except in the cases set out in Sections V.7 and VIII of the Communiqué, these invoices cannot be issued on paper (509 SN Tebliğ IV.1.1, IV.2.4.3).
e-Archive Invoice (e-Arşiv Fatura): An invoice issued electronically to buyers that are not registered in the e-Invoice system (end consumers, customers abroad, unregistered companies). It is delivered to the buyer by e-mail or as a paper printout, as the buyer requests (509 SN Tebliğ IV.2.1).
e-Ledger (e-Defter): The journal (yevmiye defteri) and the general ledger (büyük defter) are generated electronically in the GİB format and submitted for GİB approval with monthly “berat” files (GİB’s electronic approval receipts). The berat files replace the notarial certification required for paper books (Elektronik Defter GT 4.3.3).

Which invoice is issued depends on the buyer. A seller registered for e-Invoice must also join the e-Archive Invoice system (IV.2.4.1). That seller issues an e-Invoice to a buyer registered for e-Invoice, and an e-Archive Invoice to a buyer that is not registered, whether or not that buyer is a taxpayer (509 SN Tebliğ IV.1.1, IV.2.1). Whether a buyer is registered is checked in the list of registered users that GİB publishes on ebelge.gib.gov.tr (IV.1.4/ç).

e-Invoice: Who Must Switch and When

General Revenue Threshold: 3 Million TL

Taxpayers whose gross sales revenue for 2022 or any later accounting period is 3 million TL or more must switch to e-Invoice (509 SN Tebliğ IV.1.4/a-1). This threshold has also remained unchanged for the 2025 and 2026 accounting periods. A taxpayer that exceeds the threshold must use e-Invoice from the beginning of the seventh month of the year following the relevant accounting period, that is, from 1 July (IV.1.5/a). Accordingly, for a company whose 2026 revenue reaches 3 million TL, the latest transition date is 1 July 2027.

Sector-Specific Obligations

For certain activities, the obligation applies regardless of revenue or at lower thresholds (IV.1.4 and IV.1.5). These are:

Lower revenue threshold: For businesses selling goods or services through their own website or through marketplaces, and for those buying, selling or leasing real estate or motor vehicles, the threshold for 2022 and later periods is 500,000 TL.
Obligation regardless of revenue: e-commerce intermediary service providers and online advertising intermediaries, fuel businesses licensed by the Energy Market Regulatory Authority (EPDK), manufacturers and importers of goods on list (III) of the special consumption tax (ÖTV), fruit and vegetable traders and commission agents, healthcare providers contracted with the Social Security Institution (SGK), hotels holding a tourism operation certificate (turizm işletme belgesi), and electric vehicle charging network operators.
Transition period: For new businesses in these groups, the transition period varies by activity and is in most cases limited to a few months after the start of business. You need to check before incorporation whether your activity falls within one of these lists.

Newly Incorporated Companies

Communiqué No. 509 contains no e-Invoice obligation linked to the amount of share capital. A newly incorporated company is subject to the revenue and sector rules above. There are, however, two special cases:

If a sole proprietorship (şahıs işletmesi) that is within the scope of the obligation is converted into a capital company, the new company must also switch to e-Invoice within three months at the latest (IV.1.4/g).
The same three-month period applies to companies resulting from a merger, a demerger or a change of legal form (nevi değişikliği) (IV.1.4/e).

Companies outside the scope of the obligation may switch to e-Invoice voluntarily at any time (IV.1.4/d). In practice, many corporate customers expect e-Invoices from their suppliers, so an early voluntary switch is often chosen for commercial reasons. A company that switches voluntarily can no longer issue paper invoices to registered buyers from that point on.

e-Archive Invoice: Amount Threshold Removed in 2026

Every taxpayer that switches to e-Invoice must also join the e-Archive Invoice system within the same transition period (509 SN Tebliğ IV.2.4.1). Registered buyers thus receive e-Invoices, and all other buyers receive e-Archive Invoices.

For taxpayers that have not joined the e-Archive system, the rule has changed significantly over the last two years (IV.2.4.3):

In the early years of the system, only invoices issued to taxpayers exceeding 5,000 TL including taxes, and invoices issued to non-taxpayers exceeding 30,000 TL, were issued as e-Archive invoices through the GİB portal (GİB FAQ on Communiqué No. 509, 509 SN Tebliğ Sıkça Sorulan Sorular, question 30). These thresholds no longer apply.
Under Communiqué No. 573 (Sıra No: 573 Tebliğ, published in the Official Gazette (Resmî Gazete, RG) on 12.11.2024), invoices exceeding 3,000 TL including taxes began to be issued as e-Archive invoices in the period 1 January 2025 to 31 December 2025.
From 1 January 2026, all invoices must be issued as e-Archive Invoices regardless of amount (Sıra No: 573 Tebliğ m. 2 and 20).
Communiqué No. 589 (Sıra No: 589 Tebliğ, RG 31.12.2025) postponed this change by one year only for taxpayers taxed under the simplified method (basit usul) and those keeping books on the business account basis (işletme hesabı esası). For these taxpayers the 3,000 TL threshold applies until 31 December 2026, and the amount threshold is removed on 1 January 2027. Because limited and joint stock companies keep their books on the balance sheet basis (bilanço esası), this postponement does not cover companies.

As a result, a company incorporated in 2026 can issue only e-Archive Invoices from its very first invoice, even if it is not registered for e-Invoice. This also covers service export invoices issued to customers abroad. A company that has not joined the e-Archive system issues these invoices on GİB’s e-Document (e-Belge) portal (IV.2.4.3). To issue e-Archive Invoices through a private integrator, the company must first register for both e-Invoice and e-Archive Invoice (IV.2.2). Except in the cases listed in Section V.7 of the Communiqué, such as a system failure or a fault in the financial seal, and the exceptions in Section VIII, issuing a paper invoice, or accepting a paper invoice where the buyer is a taxpayer rather than an end consumer, triggers the penalty under VUK Art. 353 for each invoice (IV.2.4.3).

e-Ledger: Mandatory for Every Company on the Balance Sheet Basis

Under the Electronic Ledger General Communiqué, three groups must keep e-Ledgers (EDGT 3.2.1):

taxpayers required to switch to e-Invoice;
companies subject to independent audit (bağımsız denetim) under Art. 397/4 of the Turkish Commercial Code (Türk Ticaret Kanunu);
the group added by Communiqué No. 5 (Sıra No: 5 Tebliğ, RG 08.11.2024): taxpayers required to keep books on the balance sheet basis or that choose this basis voluntarily.

Limited and joint stock companies always keep their books on the balance sheet basis. They have therefore been required to keep e-Ledgers since 1 January 2025, whatever their revenue. For companies that started business on or after 1 January 2025, the obligation applies from the start date (EDGT 3.2.6/3). Consequently, a company incorporated in 2026 cannot have a paper journal certified. Books kept on paper despite the obligation are deemed not to have been kept at all, and GİB opens an e-Ledger account ex officio (re’sen) for taxpayers that do not apply (EDGT 3.2.10).

For taxpayers that move to e-Ledger because of the e-Invoice obligation, the rule is as follows: e-Ledger starts within the e-Invoice transition period. Those that become obliged to switch to e-Invoice during the year keep e-Ledgers from 1 January of the following year (EDGT 3.2.6/1). For new companies this distinction usually loses its relevance, because e-Ledger has already started on incorporation owing to the balance sheet basis.

Berat files are generated monthly. Corporate taxpayers (kurumlar vergisi mükellefleri) upload the berat for each month by the 14th of the fourth month following that month (for example, 14 July for the March period). Taxpayers may also choose to upload by provisional tax periods (geçici vergi dönemleri) (EDGT 4.3.4). GİB may extend these deadlines by circular (sirküler) (EDGT 4.3.6), so the announcements on edefter.gov.tr should be followed. We explain in detail how the ledger is kept technically, together with the berat and retention processes, in our article How to Keep an e-Ledger.

Ministry of Trade ETDS: A System Separate From GİB’s e-Ledger

GİB’s e-Ledger (e-Defter) application and the Ministry of Trade’s Electronic Commercial Books System (Elektronik Ticari Defter Sistemi, ETDS) are different systems. The e-Ledger is based on the VUK and covers the accounting books (the journal and the general ledger, and optionally the inventory book). ETDS was set up by a joint communiqué of the Ministry of Trade and the Ministry of Treasury and Finance and covers non-accounting commercial books (Communiqué on Keeping Non-Accounting Commercial Books Electronically, İşletmenin Muhasebesiyle İlgili Olmayan Ticari Defterlerin Elektronik Ortamda Tutulması Hakkında Tebliğ, RG 14.02.2025, Art. 2 and 5). Books kept in ETDS are not uploaded to GİB and are not approved with an e-Ledger berat. An e-Ledger application does not replace ETDS registration either.

For companies whose formation is registered with the trade registry (ticaret sicili) on or after 1 January 2026, the position in ETDS is as follows (Communiqué Art. 5/1-a, as amended on RG 20.09.2025):

Share ledger (pay defteri): must be kept in ETDS.
General assembly meeting and minutes book (genel kurul toplantı ve müzakere defteri): must be kept in ETDS.
Board of directors’ or board of managers’ resolution book (yönetim kurulu veya müdürler kurulu karar defteri): keeping it in ETDS is optional. The company may keep this book in ETDS or as a physical book.

According to the Ministry of Trade’s ETDS roadmap, the ETDS system user for these companies is defined while the articles of association are prepared in MERSİS, or by a form submitted to the trade registry office. The books become active in ETDS automatically when the formation is registered. In its announcement of 18 December 2025, the Ministry stated that keeping the board of directors’ resolution book electronically is left to the company’s choice.

Summary Table: Who Must Switch and When

Situation	e-Invoice	e-Archive Invoice	e-Ledger
Ltd./A.Ş. incorporated in 2026, revenue below 3 million TL, not within a sector-specific scope	Not mandatory; voluntary switch possible	All invoices as e-Archive, on GİB’s e-Document portal (IV.2.4.3). A private integrator requires prior e-Invoice and e-Archive registration (IV.2.2)	Mandatory from the incorporation date (EDGT 3.2.6/3)
2026 gross sales revenue of 3 million TL or more	From 1 July 2027 (IV.1.5/a)	Joins the system on the same date as e-Invoice (IV.2.4.1)	Already mandatory (balance sheet basis)
Online seller with 2026 revenue of 500,000 TL or more	From 1 July 2027 (IV.1.4/a-4, IV.1.5)	On the same date (IV.2.4.2)	Already mandatory
e-commerce intermediary service provider, online advertising intermediary, licensed fuel business, hotel, etc.	Regardless of revenue, within the activity-specific period (IV.1.4, IV.1.5)	Together with e-Invoice	Already mandatory
Company subject to independent audit	Not mandatory unless a revenue or sector condition also applies	IV.2.4.3 rule until it switches to e-Invoice	From 1 January following the year in which the condition is met
Sole proprietorship under the simplified method or business account basis	Depends on the revenue or sector condition	Above 3,000 TL in 2026; all invoices from 1/1/2027 (Sıra No: 589)	Not mandatory on the business account basis

GİB Portal or Private Integrator

The e-Document (e-Belge) systems can be used through three methods (509 SN Tebliğ V.1):

GİB Portal method (V.1.1): GİB’s free web interface. Taxpayers that are not registered for e-Invoice can issue e-Archive invoices on the e-Document portal without filing an application, using their Interactive Tax Office (interaktif vergi dairesi) login details. These invoices are retained by GİB for the statutory period (GİB SSS 31, 32 and 40). GİB has stated that there is no limit on the number of documents on its portals (GİB SSS 35). However, the portal is based on manual entry and offers no automatic connection to accounting or ERP software.
Private integrator method (V.1.2): Use through a private integrator (özel entegratör) authorised by GİB. The integrator automatically receives invoices from the company’s accounting or sales software, transmits them to GİB and stores them. The service is paid. It is generally more suitable for companies with a high invoice volume, several branches, or a need to integrate with the systems of group companies abroad. Integrators that breach the rules may have their authorisation revoked. In that case, their customers move to another integrator or to the GİB portal (V.1.2, VII).
Direct integration (V.1.3): The company connects its own system to GİB. Since Communiqué No. 573, this method is open only to taxpayers that meet the size, sector and IT requirements set by GİB.

To register for e-Invoice, legal entities must obtain a financial seal (mali mühür) from TÜBİTAK BİLGEM Kamu SM. Individuals use a qualified electronic certificate (e-signature, e-imza) (509 SN Tebliğ V.9). Different methods and different integrators may be chosen for e-Archive and e-Invoice (GİB SSS 38–39). When choosing, the monthly number of invoices, the accounting software in use, the need for invoices in a foreign language and group reporting should be taken into account. The scope of our work on setting up invoicing processes is described on our Invoicing and e-Invoice page.

Penalties: VUK Art. 353 and 2026 Amounts

If an invoice that must be issued as an electronic document is issued on paper, the document is deemed not to have been issued at all. In that case, a special irregularity penalty (özel usulsüzlük cezası) of 10% of the amount that should have been shown on the document is imposed (VUK m. 353/1). The amounts applicable in 2026 were set by VUK General Communiqué No. 588 (RG 31.12.2025, revaluation rate (yeniden değerleme oranı) 25.49%):

For the first finding in a calendar year, the minimum penalty per document is 17,000 TL.
For subsequent findings, the minimum amount rises in steps: 35,000 TL for the second, 53,000 TL for the third, 70,000 TL for the fourth, 87,000 TL for the fifth, and 170,000 TL for the sixth and later findings (Schedule No. 2 annexed to the VUK, 2 sayılı cetvel).
The total penalty imposed for each document type in a calendar year cannot exceed 17,000,000 TL.

Books kept on paper instead of as e-Ledgers despite the obligation are deemed not to have been kept (EDGT 3.2.10). If the taxpayer fails to make the mandatory switch, the penalties under the VUK apply (EDGT 3.2.11). Books being deemed not kept may also cause problems in a future tax audit for rights that depend on presenting books and documents.

Calculation example (2026 calendar year, first finding): Assume that in 2026 a company issued on paper three invoices that it should have issued as e-Archive invoices. The invoice amounts including taxes are 40,000 TL, 120,000 TL and 300,000 TL. The rate applied is 10%, and the minimum amount for the first finding is 17,000 TL per document.

40,000 TL × 10% = 4,000 TL. As this is below the minimum amount, the penalty is 17,000 TL.
120,000 TL × 10% = 12,000 TL. As this is also below the minimum amount, the penalty is 17,000 TL.
300,000 TL × 10% = 30,000 TL. As this is above the minimum amount, the penalty is 30,000 TL.
Total: 17,000 + 17,000 + 30,000 = 64,000 TL.

If the buyers are taxpayers, they may also face a separate penalty for accepting the paper invoices (509 SN Tebliğ IV.2.4.3).

Sample Timeline for a New Company with a Foreign Shareholder

Assume that A Limited Şirketi, set up by a shareholder resident in Germany, was registered with the trade registry in Istanbul on 16 March 2026. The company provides software services and does not fall within any of the sector lists above. Its gross sales revenue for 2026 is 3,400,000 TL. The company’s timeline is as follows:

March 2026: The e-Ledger application is filed, and the books are kept as e-Ledgers from the start of business (EDGT 3.2.6/3). In addition, because the company was registered after 1 January 2026, its share ledger and its general assembly meeting and minutes book become active in the Ministry of Trade’s ETDS on registration. Keeping the resolution book in ETDS is optional. This step is separate from the GİB e-Ledger application.
From the first invoice: e-Archive Invoices are issued to all customers in Türkiye and abroad, regardless of amount (IV.2.4.3).
14 July 2026: Last day for uploading the e-Ledger berat for the March 2026 period (monthly option, EDGT 4.3.4).
End of 2026: Since 3,400,000 TL ≥ 3,000,000 TL, the e-Invoice condition is met (IV.1.4/a-1).
1 July 2027: The e-Invoice and e-Archive Invoice applications are completed by this date, and from this date only e-Invoices are issued to registered buyers (IV.1.5/a, IV.2.4.1).

The company may also switch to e-Invoice voluntarily before this date. For the other tax and social security (SGK) registrations after incorporation, see our guide The First 90 Days After Company Formation; for the incorporation process with foreign shareholders, see our page Company Formation with Foreign Shareholders.

Practical Steps for the Transition

Before incorporation, check whether your field of activity falls within the sector lists in Communiqué No. 509.
Apply early for the financial seal or e-signature, as the time needed to obtain it may affect the transition date.
Choose the method (GİB portal, private integrator or direct integration) and confirm that your accounting software is e-Ledger compatible.
Monitor gross sales revenue during the year. Once the 3 million TL threshold (500,000 TL for online sales) is exceeded, mark 1 July of the following year in your calendar.
Keep enough pre-printed documents (matbu belge) for outages. Paper documents may be used only in the cases of system failure, financial seal failure and similar situations listed in Section V.7 of the Communiqué. Under Section VIII, taxpayers that have just joined e-Invoice and e-Archive Invoice may also issue paper documents until the end of the seventh day; only one document is issued for the same transaction.
Regularly monitor the berat upload deadlines and any extensions made by GİB circulars.

For the scope of our work on statutory books and the e-Ledger process, see our Statutory Books and e-Ledger page. For your company’s specific situation, you can write to us through our contact page.

Last legislation check: 9 November 2026 · Period covered: calendar year 2026 and the 1 July 2027 e-Invoice transition based on 2026 revenue

e-Invoice, e-Archive Invoice and e-Ledger in Türkiye: A Transition Guide for New Companies