Who Is Required to Transition to Electronic Commercial and E-Ledgers?

The Ministry of Trade and the Ministry of Treasury and Finance have introduced a new regulation requiring certain companies to maintain their commercial ledgers electronically:

• Companies registered in the trade registry as of January 2026

• Banks, financial leasing, factoring, consumer finance, and card services companies

• Insurance companies, holding companies established as joint-stock corporations, currency exchange offices, and companies engaged in public warehousing

• Independent audit and supervision firms, agricultural licensed warehousing companies, and product specialized exchanges

• Technology development zone management companies, free zone founders, and operators

• Companies subject to the Capital Markets Law

  
  

Companies falling under this regulation must maintain their share ledgers, board of directors’ resolution ledgers, managers’ resolution ledgers, and general assembly meeting and negotiation ledgers in electronic format.

Transition Process and Implementation Details

What is an electronic ledger, and why is it necessary?An electronic ledger is a system that securely maintains commercial records in digital format. It prevents data loss, streamlines audit processes, and reduces paper usage, contributing to environmental sustainability.

How will companies transition to electronic ledgers?The electronic ledger system will be managed through the Electronic Ledger System developed by the Ministry of Trade. Companies will access the system through authorized personnel and securely maintain their commercial records.

• Newly established companies will have their commercial ledgers activated in the system upon completion of trade registry registration.

• Companies currently maintaining physical ledgers and wishing to transition to electronic ledgers must apply to a notary with the resolution template provided in Annex-1 of the Communiqué. The notary will officially close the physical ledger, record the transition, and activate the electronic ledger.

  
  

Can companies revert to physical ledgers after transitioning?No, companies that switch to electronic ledgers cannot revert to physical ledgers. Therefore, the transition process must be carefully planned.

How will electronic ledgers be stored and audited?Electronic ledgers will be secured with a digital signature or financial seal and stored for audit purposes, ensuring accessibility when required by the authorities.

Compliance Process and Penalties

What should companies consider during the compliance process?

• Companies must prepare their system infrastructure in advance.

• Authorized users should be designated, ensuring proper system management.

• Electronic ledgers must be securely maintained and remain accessible for audits.

  
  

What penalties apply to non-compliant companies?Companies that fail to transition to electronic ledgers or do not comply with the regulations will face administrative fines under the Tax Procedure Law and relevant legislation.

Conclusion and Recommendations

The new Communiqué mandates that certain sectors maintain commercial ledgers in electronic format. Companies falling within its scope must complete the transition by July 1, 2025. Company management and relevant departments must meticulously oversee the process to ensure full legal compliance.