What Are an SMMM and a YMM in Türkiye, and Must Companies Use One?

A Serbest Muhasebeci Mali Müşavir (SMMM), a licensed public accountant under Law No. 3568, is a professional who keeps a business’s books, prepares its financial statements and tax returns, and gives advice. A Yeminli Mali Müşavir (YMM), a sworn financial advisor licensed under the same law, by contrast, does not keep books; a YMM examines and certifies financial statements, tax returns and certain transactions. No law tells companies to “sign a contract with an SMMM”. However, companies below certain thresholds must have their corporate tax, VAT (KDV) and combined withholding tax and social security returns (muhtasar ve prim hizmet beyannamesi) signed by a licensed professional, and a company newly formed in 2026 falls within this scope. Working with a YMM is not mandatory except in limited cases; for some VAT refunds, for example, a YMM report is one of the options alongside a tax audit report or a guarantee.

What Is an SMMM (Licensed Public Accountant)

The profession is governed by Law No. 3568 on Certified Public Accountancy and Sworn Financial Advisory (Serbest Muhasebeci Mali Müşavirlik ve Yeminli Mali Müşavirlik Kanunu). Under the law, an SMMM’s field of work is to carry out the following tasks without being an employee of the business (Law No. 3568, Art. 2/A):

• keeping the books in accordance with generally accepted accounting principles and standards, and preparing balance sheets, income statements and tax returns;
• setting up accounting systems and advising on tax and financial legislation;
• examining, analysing and auditing documents and records, and preparing written opinions, reports and expert witness reports.

In practice, this covers keeping the statutory books and the e-ledger (e-Defter), preparing the monthly VAT returns and the combined withholding tax and social security returns, preparing the annual corporate tax return (kurumlar vergisi beyannamesi), and payroll filings. For how the e-ledger works, see our e-ledger guide; for the transition to e-invoice (e-Fatura) and e-archive (e-Arşiv), see our e-document guide.

Comparison With a CPA or Chartered Accountant

Foreign investors often equate the SMMM with a “CPA” or a “chartered accountant”. The comparison is apt in that it is an accounting profession regulated by law, entered by examination and requiring registration with a professional chamber. It does not fully fit on three points:

• Certification is a separate title. The authority to certify tax returns and financial statements vis-à-vis the tax administration, with joint and several liability, lies with the YMM, not the SMMM (Law No. 3568, Art. 2/B, 12).
• Independent audit is a separate authorisation. Independent audits (bağımsız denetim) under the Turkish Commercial Code (Türk Ticaret Kanunu, TTK) may be carried out by YMMs or SMMMs authorised by the Public Oversight, Accounting and Auditing Standards Authority (Kamu Gözetimi, Muhasebe ve Denetim Standartları Kurumu, KGK), or by audit firms in which they are partners (TTK Art. 400/1). The SMMM title alone does not confer authority to act as an auditor.
• A foreign title confers no authority in Türkiye. Persons not legally authorised may not use the SMMM or YMM title (Law No. 3568, Art. 3), and persons who are not members of a chamber may not practise the profession (Art. 15). A CPA, ACCA or similar foreign qualification does not give the right to practise these professions in Türkiye.

Who Can Become an SMMM

The general requirements include being a Turkish citizen, having full legal capacity and not having been convicted of certain offences (Law No. 3568, Art. 4). The profession-specific requirements are (Art. 5, 6):

1. a university degree in law, economics, public finance, business administration, accounting, banking, public administration or political science;
2. passing the traineeship entrance examination and completing a traineeship of at least three years;
3. passing the SMMM examination;
4. obtaining an SMMM licence and registering with the chamber.

There is a separate provision for foreign nationals: citizens of a country where the profession is regulated by law may work under the SMMM title, provided that they meet the qualifications required of Turkish citizens, reciprocity exists and the President’s approval is obtained (Art. 8). In other words, the Turkish examination and licensing requirements also apply to a foreign professional.

What Is a YMM (Sworn Financial Advisor)

A YMM is a professional who, in addition to the advisory and examination work of an SMMM, performs certification (tasdik) (Law No. 3568, Art. 2/B). Certification means examining the records in accordance with auditing standards and determining, under signature and seal, whether the documents being certified reflect the true position (Certification Regulation, Art. 4). A YMM is jointly and severally liable with the taxpayer, limited to the scope of the certification, for taxes and penalties arising from inaccuracies in the documents the YMM has certified (Law No. 3568, Art. 12).

To become a YMM, a person must have worked as an SMMM for at least 10 years, pass the YMM examination and obtain a licence (Art. 9); before starting work, a YMM takes an oath before the commercial court of first instance (asliye ticaret mahkemesi) (Art. 11).

An important limit: YMMs may not keep accounting books, open an accounting office or become partners in accounting offices (Law No. 3568, Art. 2/B). For this reason, the professional who keeps a company’s books and the professional who certifies its tax returns are different people.

The regulation lists the matters subject to certification by type of tax, such as annual income and corporate tax returns with the attached financial statements, transactions giving rise to VAT refunds, incentive, deduction and exemption transactions, and requests for deferral and write-off (Certification Regulation, Art. 7). Certification of the annual corporate tax return is known in practice as full certification (tam tasdik); the contract for it is concluded within the first month of the relevant tax period (Art. 10).

Are Companies Required to Work With an SMMM

Four separate matters fall under this heading:

• Having returns signed: certain tax returns must be signed by a professional authorised under Law No. 3568. Whether this applies depends on the thresholds below.
• Acting as e-return intermediary: this concerns whose user code is used to submit the return to the Revenue Administration (Gelir İdaresi Başkanlığı) system. It is an authorisation and contractual relationship separate from the signature.
• Bookkeeping: the obligation to keep the books lies with the company itself. The books may be kept in-house by an employee or externally by an SMMM.
• YMM full certification: certification of the annual corporate tax return and the attached financial statements by a YMM. It is a different act from an SMMM’s signature and is optional except in the cases listed below.

As regards contracts and signatures, the legal position has two layers.

No Contract Requirement, but a Signature Requirement

In the legislation we reviewed, there is no provision requiring companies to sign a contract with an SMMM or to outsource their bookkeeping. On the other hand, the Tax Procedure Law (Vergi Usul Kanunu, VUK) empowers the Ministry to require that tax returns be signed by professionals authorised under Law No. 3568 (VUK supplementary Art. 227/1). Under the communiqués based on this power:

• corporate taxpayers, and income taxpayers taxed on the actual-income basis for commercial, agricultural or professional income, whose total assets and net sales in the previous year do not exceed the set amounts must have their annual corporate or income tax return, their combined withholding tax and social security return and their VAT returns signed by a licensed professional (General Communiqué on the Signing of Tax Returns by SMs and SMMMs No. 4 (Vergi Beyannamelerinin SM ve SMMM’lerce İmzalanması Hakkında Genel Tebliğ Sıra No: 4), sections II/A, II/B and C);
• the amounts are increased each year by the previous year’s revaluation rate (yeniden değerleme oranı); fractions of 500 TL or less are disregarded, and fractions above that are rounded up to 1,000 TL (General Communiqué on Law No. 3568 No. 37, section 3);
• a taxpayer that has its income or corporate tax return certified by a YMM is not additionally required to have it signed by an SMMM.

A taxpayer that fails to have its returns signed is subject to an irregularity penalty (usulsüzlük cezası), and the case is also referred to the assessment commission for an ex officio assessment (Communiqué No. 4; VUK Art. 30/8). The signing professional is also liable, together with the taxpayer, for the tax, penalties and interest arising if the return does not match the books and documents (VUK supplementary Art. 227/2).

Amounts for Returns Filed in 2026

The amounts below have been calculated by applying the revaluation rate to the prior-year thresholds, following the rule in Communiqué No. 37; they have not been confirmed by a separate official announcement. The revaluation rate for 2025 is 25.49% (VUK General Communiqué No. 585). The amounts applied in 2025 were calculated in the same way. The calculation is as follows:

For returns filed in 2027, the amounts will be updated in the same way with the 2026 revaluation rate and applied to 2026 financial year figures. Companies exceeding either of these two amounts fall outside the signing requirement; Communiqué No. 4 refers these taxpayers to YMM certification. The Certification Regulation, however, states that certification is, as a rule, carried out at the request of the party concerned (Art. 9/1). The position of companies of this size should be assessed separately.

Who Submits the e-Return

Tax returns are filed electronically. Taxpayers that meet the conditions for submitting their own returns may do so themselves with a user code, password and PIN; those that do not meet the conditions submit them through persons holding e-return (e-beyanname) intermediary authorisation, under a contract concluded between them. A return submitted through a professional is deemed to have been filed by the taxpayer (VUK General Communiqué No. 528, Art. 2/4-5; General Communiqué on the Combined Withholding Tax and Social Security Return No. 1 (Muhtasar ve Prim Hizmet Beyannamesi Genel Tebliği Sıra No: 1), Art. 7). Intermediation is a separate matter from the signature: the signature makes the professional responsible for the content of the return, while intermediation concerns its electronic submission. In practice, the professional who signs the return often also submits it as intermediary.

Bookkeeping: Legal Requirement and Practice

The obligation to keep the books lies with the company itself. The law does not prohibit the books from being kept in-house by an employee of the company. Even if the company has its own accounting team, the returns within the signing requirement must be signed by an SMMM or a YMM. Whether the books are kept in-house or externally is the company’s own choice.

Are Companies Required to Work With a YMM

There is no general YMM requirement for an ordinary limited company (limited şirket) or joint stock company (anonim şirket). The cases that can be verified are the following:

Full Certification

Certification is carried out at the request of the party concerned (Certification Regulation, Art. 9/1). The regulation also states that banks, insurance companies, foreign trade capital companies (dış ticaret sermaye şirketleri), companies that are publicly held under the Capital Markets Law, brokerage firms, investment trusts and funds, and other companies the Ministry deems necessary are to have their annual financial statements and tax returns certified (Art. 9/2). For a company outside these groups, full certification is optional.

VAT Refunds

For VAT refunds, a YMM report is one of the routes listed in the Communiqué. The example of exports of goods (VAT General Implementation Communiqué (KDV Genel Uygulama Tebliği) II/A-1.1.4.1):

• Refund by offset (setting the refund receivable off against tax debts): once the required documents are submitted, no tax audit report, YMM report or guarantee is required, regardless of the amount.
• Cash refund: claims not exceeding 50,000 TL are paid without a tax audit report, YMM report or guarantee. The excess is refunded on the basis of a tax audit report or a YMM report. If a guarantee is provided, the refund is made and the guarantee is released according to the outcome of the report.

The 50,000 TL limit has applied since 31 October 2024 (Communiqué Serial No. 52). The rules differ for some types of refund: for example, cash refunds arising from certain services subject to partial VAT withholding (tevkifat) are made only against a guarantee and/or a tax audit report; if a full certification contract was concluded on time for the year in which the transaction giving rise to the refund took place, a YMM report may also be used (Communiqué I/C-2.1.5.2.2). If a refund has been requested with a YMM VAT Refund Certification Report, no refund is made until the report is submitted; a guarantee may be provided while the report is pending (Communiqué IV/A3-4, IV/A3-5). As the topic is detailed, you can find a general overview on our indirect tax page.

Other Matters Subject to Certification

Incentive, deduction, exemption, deferral and write-off transactions are also among the matters subject to certification (Certification Regulation, Art. 7). Whether a YMM report is mandatory for these transactions is determined by the relevant specific legislation; this article covers only VAT refunds in detail.

How It Differs From an Independent Auditor

An independent audit is the audit of financial statements in accordance with the Turkish Auditing Standards (TTK Art. 397/1). The President determines which companies are subject to audit (TTK Art. 397/4). Under Presidential Decree No. 6434, companies not on the special lists become subject to audit from the following period if they exceed at least two of the three criteria below in two consecutive financial years (Decree Art. 3/1-b-3, 5/1):

• total assets of 500 million TL;
• annual net sales revenue of 1 billion TL;
• 150 employees.

These amounts were set by Presidential Decree No. 11066 (RG 17.03.2026, 33199) and are the basis for determining whether a company is subject to audit for financial years beginning on or after 1 January 2026 (KGK announcement 2026-12).

SMMM, YMM and Independent Auditor Compared

Example: A Limited Company With a Foreign Shareholder in Its First Year

Assumption: A limited company whose shareholder is a company resident in Germany was formed in Istanbul in March 2026. It provides consultancy services in Türkiye, has two employees and expects its total assets to be around 10 million TL at the end of 2026.

1. Scope of the signing requirement: The scope is determined by total assets and net sales in the year before the year in which the return is filed. Since the company had no activity in 2025, it has not exceeded the calculated amounts of 115,209,000 TL and 230,359,000 TL for returns filed in 2026; on the wording of the communiqué, it is within the signing requirement. For returns filed in 2027, the test is total assets at the end of 2026 (around 10 million TL) and 2026 net sales. As these are far below the amounts to be updated, the company also remains within the scope in 2027.
2. Books and e-documents: The books and the e-ledger are kept from the start of business. For the first steps, see our guide to the first 90 days after formation; for the scope of the bookkeeping service, see our statutory books page.
3. Return types and periods: The returns to be filed with a licensed professional’s signature are: the VAT return, for each month starting with the March 2026 period; the combined withholding tax and social security return, from the period in which salary payments and the employment of insured staff begin (as a rule, monthly); and the annual corporate tax return for the 2026 financial year, running from the formation date to 31.12.2026, filed in 2027. Submitting these returns through the e-return system additionally requires an intermediary contract. For the types of return, see our tax returns page.
4. YMM: The company does not fall within the groups in Certification Regulation Art. 9/2. Full certification is optional. If the company later starts exporting goods and requests a cash VAT refund exceeding 50,000 TL, one of the routes for the excess (a YMM report, a tax audit report or a guarantee) becomes relevant.
5. Independent audit: As its total assets, net sales and number of employees are far below the thresholds, it is not subject to audit.

Fees and the Minimum Fee Schedule

A minimum fee schedule (asgari ücret tarifesi) for professionals’ fees is set each year. TÜRMOB (the Union of Chambers of Certified Public Accountants and Sworn Financial Advisors of Türkiye) prepares the schedule on the proposals of the chambers, the Ministry of Treasury and Finance approves it, and it is published in the Official Gazette (Resmî Gazete). Accepting work below the minimum amount in the schedule is prohibited and leads to a disciplinary penalty (Law No. 3568, Art. 46). The 2026 schedule was published in Official Gazette No. 33110 of 17 December 2025 and entered into force on 1 January 2026. As the amounts vary by type of work and region, they are not given in this article.

KEYBIZ CPAs & Advisors is an SMMM firm; it is not a YMM and does not issue full certification or YMM reports. For questions specific to your company, you can write to us via our contact page.

Last legislation check: 9 November 2026 · Period covered: returns filed in 2026 (2025 financial year) and the 2026 financial year