Under General Communiqué No. 49 on the Law of Independent Accountancy, Financial Advisory, and Sworn-in Financial Advisory, published in the Official Gazette dated December 30, 2025 (No. 33123), income and corporate taxpayers must now submit a certification report prepared by a Sworn-in Certified Public Accountant (YMM) in order to benefit from certain exemptions, deductions, and applications reported on their tax returns. In this article, we summarize the scope of this certification requirement, the monetary thresholds, and the consequences of failing to submit the report.
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What Does the Certification Requirement Cover?
Importantly, this requirement is not a blanket obligation covering all exemptions and deductions on a tax return. It applies only to the specific exemptions, deductions, and applications listed in the table under the second paragraph of Article 4 of the Communiqué. The regulation applies from corporate tax returns for the 2025 fiscal year onward, directly affecting returns filed in 2026.
What Are the Monetary Thresholds?
The certification requirement is triggered by the following thresholds:
- Amounts exceeding TRY 500,000 for each individual exemption/deduction item shown on a separate line of the return,
- Amounts exceeding TRY 1,000,000 for the combined total of these items.
If either threshold is exceeded, a YMM certification report becomes mandatory for the relevant exemption/deduction. For income taxpayers, the requirement covers certain items shown on separate lines of the return; for corporate taxpayers, the scope is broader, covering 21 separate categories. Importantly, this regulation does not only apply to high-revenue “full certification” taxpayers — it also applies to businesses with lower revenue that report a significant exemption or deduction amount on their return.
Report Deadline and Submission Method
Certification reports must be submitted electronically through the Digital Tax Office within 2 months following the tax return filing deadline (3 months for real estate investment trust earnings). Taxpayers who already have a full certification agreement do not need to submit a separate report, provided the matters covered by the Communiqué are included in their full certification report; however, YMMs remain jointly and severally liable with the taxpayer for the accuracy of the certification.
What Happens If the Report Isn’t Submitted?
If the certification report is not submitted on time, the process works as follows:
- The taxpayer is given an additional grace period to submit the report.
- If the report is still not submitted by the end of this grace period, the taxpayer loses the right to benefit from the relevant exemption or deduction.
- A special irregularity penalty also applies (set at TRY 330,000 for 2025).
Recommendations for Taxpayers
- Check in advance whether the exemption and deduction items on your return exceed the TRY 500,000 / TRY 1,000,000 thresholds.
- If you do not have a full certification agreement and have an exemption/deduction exceeding the thresholds, remember that a standalone YMM certification report is required for that specific item.
- Start the certification process immediately after filing your tax return; don’t leave the 2-month (or 3-month, for REITs) window until the last day.
- Work with your CPA to confirm which of your exemptions/deductions fall under the table in Article 4 of the Communiqué — not every exemption or deduction is covered.
At Mete CPA & Auditing, we support you from determining whether the exemptions and deductions on your tax return fall under the certification requirement, to ensuring your YMM certification report is completed accurately and on time. Contact us to review your situation.
