In short: Accounting and financial consultancy in Türkiye is a regulated professional field. The legal framework may involve Law No. 3568, TÜRMOB and local chambers, the Revenue Administration, KGK, MASAK and the Personal Data Protection Authority.
Why it matters: An accounting firm’s legal risk can extend beyond a client contract. Professional licensing, tax declarations, audit authorization, AML, KVKK, confidentiality, employment, fee collection and disciplinary rules may all affect the same engagement.
How We Assist Accounting and Audit Firms in Türkiye
Turkish Trade Lawyers advises SMMM firms, YMM practices, independent audit companies, international accounting networks and financial consultancy businesses.
Professional regulatory advice
Law No. 3568, professional regulations, chamber requirements and TÜRMOB rules.
Establishment and restructuring
Company formation, partnerships, shareholder changes, governance and professional-practice structures.
KGK and audit matters
Authorization, corporate changes, compliance reviews, investigations and administrative sanctions.
Engagement agreements
Accounting, payroll, certification, audit-support and financial consultancy agreements.
Professional liability
Claims involving accounting treatment, filing errors, tax losses, missed deadlines or negligence.
Disciplinary proceedings
Representation in complaints and disciplinary investigations involving SMMM and YMM professionals.
MASAK and KVKK compliance
AML procedures, client identification, data mapping, privacy documents and international transfers.
Partner disputes and fee collection
Professional exits, client portfolios, share transfers, demands, enforcement and litigation.
Employment matters
Employment agreements, confidentiality, departures, restrictive covenants and disputes involving staff.
Cross-border accounting networks
Turkish-law review of branding, shared services, secondments, technology and data transfers.
Who Regulates Accounting Firms in Türkiye?
Several public and professional bodies may have authority over an accounting or audit practice, depending on the services it provides. A legal review should identify the firm’s professional category, service scope, authorization status and client-facing role before selecting the applicable compliance framework.
TÜRMOB and local chambers
Law No. 3568 establishes the professional framework for Serbest Muhasebeci Mali Müşavir (SMMM) and Yeminli Mali Müşavir (YMM) professionals. TÜRMOB and the relevant chambers address professional organization, standards, membership and discipline.
Revenue Administration
The Revenue Administration operates the tax administration and electronic declaration environment. Tax Procedure Law No. 213, including repeated Article 227, may be relevant to records, declarations and responsibilities connected with professional signatures.
KGK
Where statutory independent audit services are provided, the Public Oversight, Accounting and Auditing Standards Authority is the central authorization and oversight body for auditors and audit firms.
MASAK
Independent accountants, certified public accountants and sworn-in certified public accountants working without an employer may be obliged parties under Türkiye’s anti-money laundering framework.
Personal Data Protection Authority
Payroll, bank, tax, employee, shareholder and customer records may involve personal data. Accounting firms should assess controller or processor roles, security, transparency, data-subject rights and international transfers under KVKK.
The Main Law Governing Accountants in Türkiye: Law No. 3568
The legal starting point for most professional regulatory issues involving an SMMM or YMM is Law No. 3568 on Certified Public Accountancy and Sworn-in Certified Public Accountancy (Serbest Muhasebeci Mali Müşavirlik ve Yeminli Mali Müşavirlik Kanunu). It defines the regulated professions, establishes qualification requirements, identifies professional activities and provides the institutional basis for chambers and TÜRMOB.
A lawyer advising an accounting firm must distinguish ordinary accounting-related commercial consultancy from services reserved to professionals authorized under Law No. 3568. That distinction becomes important in:
- establishing a new practice or acquiring a professional practice;
- admitting or exiting partners and changing ownership or management;
- cooperating with an international accounting network;
- using protected professional titles;
- outsourcing, transferring client portfolios or employing professional staff;
- conducting commercial activities alongside regulated services; and
- responding to disciplinary investigations or disputes about professional scope.
Law No. 3568 also separates SMMM and YMM activities. For example, the law provides that YMM professionals may not keep accounting books, open an accounting office or become partners in accounting offices. Partnership agreements, articles of association and internal governance rules should therefore be reviewed with professional legislation, not only with the Turkish Commercial Code.
SMMM, YMM and Independent Auditor: Why the Legal Distinction Matters
International businesses often use the word “accountant” broadly. Turkish legislation does not. The first legal question is which professional category and which activity are involved.
SMMM – Serbest Muhasebeci Mali Müşavir
An SMMM practice operates within the professional activities regulated under Law No. 3568. Legal work may concern establishment, professional partnerships, engagement agreements, fees, liability, tax investigations, AML, KVKK and discipline.
YMM – Yeminli Mali Müşavir
A YMM performs a distinct regulated role and may carry out certification activities attributed to the profession by Turkish law. The relevant tax legislation or communiqué must be reviewed together with Law No. 3568.
Independent auditor
Being an SMMM or YMM does not by itself authorize every statutory independent audit. Independent audit is governed by a separate KGK authorization and oversight framework affecting corporate structure, signing authority, independence and reporting.
Financial consultancy business
Non-regulated advisory work may still involve corporate, tax, contract, data and employment obligations. The service description and engagement documents should not blur the boundary between consultancy and reserved professional activity.
Accounting Firm Establishment and Corporate Structuring in Türkiye
A common mistake is to establish an ordinary limited or joint-stock company and assume that professional accounting activities can automatically be conducted through that entity. Professional structuring must also satisfy Law No. 3568 and the regulations governing professional practice.
For independent audit firms, KGK requirements go further. The authorization framework addresses matters such as capital-company status, registered shares, professional ownership, authorized auditors, responsible auditors, corporate purpose, management composition and quality-control infrastructure.
- company formation and amendments to articles of association;
- professional partnership and shareholder structures;
- entry and exit of professional partners and share transfers;
- internal governance, signature and representation authority;
- partner remuneration, restrictive covenants and succession planning;
- mergers or acquisitions involving professional practices;
- confidentiality, records and separation of regulated and non-regulated services; and
- international network membership and shared-service arrangements.
Foreign Accounting Firms and International Accounting Networks in Türkiye
A foreign accounting network entering Türkiye should not treat professional accounting services in the same way as ordinary management consulting. Professional qualification rules under Law No. 3568 should be examined before protected professional activities or titles are used in Türkiye. Independent auditing adds a separate KGK analysis, including authorization and, where relevant, reciprocity considerations for foreign audit firms and auditors.
A market-entry assessment should separately address:
- the Turkish corporate entity and permitted activities;
- professional accounting and tax services;
- professional ownership, management and signing authority;
- international brand and network names;
- independent audit authorization;
- shared-service, secondment and technology arrangements;
- international data transfers and cloud platforms;
- professional indemnity and contractual liability;
- client engagement documentation; and
- responsibility allocation between the Turkish member firm and the international network.
Independent Audit Regulation and KGK Compliance
Independent audit firms face one of the most detailed compliance frameworks within the accounting sector. The Independent Audit Regulation governs authorization, professional requirements, independence, audit activities and regulatory matters. KGK also publishes the applicable Turkish Auditing Standards and professional ethical requirements.
Legal assistance may be required for auditor independence, prohibited or conflicting non-audit services, auditor rotation, ownership or management changes, responsible auditor appointments, quality-control procedures, audit documentation, regulatory notifications, inspection findings or responses to KGK inquiries.
The KGK framework includes administrative measures such as warning, suspension of activity authorization and cancellation of activity authorization. A regulatory investigation can therefore affect the firm’s ability to continue regulated audit work, not merely result in an ordinary administrative fine.
Turkish accounting and financial reporting standards
Within its statutory remit, KGK publishes and oversees financial reporting frameworks including TMS/TFRS, BOBİ FRS and KÜMİ FRS. The applicable framework depends on the characteristics and regulatory status of the relevant entity. Identifying the correct framework is an important first step in disputes involving financial reporting, audit findings, representations or professional negligence.
Professional Liability of Accountants and Tax Declaration Risks
An accounting firm’s relationship with its client may involve contractual, professional, tax, disciplinary, regulatory and AML responsibilities. Under the framework connected with repeated Article 227 of Tax Procedure Law No. 213, professionals signing relevant declarations may bear responsibility regarding the consistency of information in declarations with accounting records and supporting documents, within the applicable statutory framework.
Client onboarding and documentation are therefore critical. The firm should be able to show what documents the client had to provide, when they were received, whether information was incomplete, which assumptions were used, who approved material accounting treatments, what the engagement covered and what services were excluded.
A carefully drafted engagement agreement combined with a documented workflow may become important evidence in a professional liability dispute.
Client Engagement Agreements for Accounting Firms
Accounting firms should not rely on a generic consultancy agreement. Depending on the services provided, the engagement should address:
- bookkeeping, payroll, tax declaration or financial consultancy scope;
- the allocation of responsibility for complete and accurate client documents;
- electronic filing authority, deadlines and document retention;
- confidentiality, personal data, third-party software and cloud services;
- fees, additional services, expenses and suspension for non-payment;
- termination, return or transfer of records and ongoing obligations;
- liability allocation, professional limitations and dispute resolution; and
- the applicable professional fee framework, including TÜRMOB tariff considerations.
Unpaid Accounting Fees and Debt Collection
Accounting firms often provide recurring services for months while unpaid invoices accumulate. We assist with overdue professional fees, formal payment demands, termination of engagements, settlement negotiations, Turkish enforcement proceedings (icra takibi), objections to enforcement, debt litigation and execution of judgments.
Where professional documents or ongoing tax obligations are involved, termination and file-transfer procedures should be handled carefully so a commercial dispute does not create a separate professional or regulatory problem.
MASAK, KVKK and Professional Ethics
MASAK and AML compliance for accounting firms
Independent SMMM and YMM professionals are expressly relevant to Türkiye’s AML framework. A compliance review may cover client identification, beneficial ownership, suspicious transaction indicators, unusual corporate structures, documentation, reporting procedures, employee awareness and confidentiality surrounding suspicious transaction reports.
An accounting firm should establish how suspicious activities are escalated internally before a MASAK inquiry arrives.
KVKK and financial data protection
Accounting firms are high-information businesses. Even a small office may process records belonging to clients’ employees, shareholders, directors, customers and suppliers. A KVKK review may include controller and processor roles, privacy notices, payroll data, access controls, accounting software, cloud storage, retention, deletion, processor agreements, incident response, data-subject applications and international transfers.
Where client data is transferred to systems outside Türkiye, the revised Article 9 regime should be assessed. Appropriate safeguards may include standard contracts and binding corporate rules where their statutory requirements are met.
Professional ethics, advertising and unfair competition
TÜRMOB rules concerning professional ethics, unfair competition and advertising may affect website wording, comparative claims, discounts, referral structures, use of professional titles and public communications. Marketing imported from an international network should be reviewed before being deployed in Türkiye.
Disciplinary Investigations Against SMMM and YMM Professionals
A professional dispute can develop into a disciplinary matter independently of civil litigation. The applicable disciplinary framework may involve warnings, reprimands, temporary prohibition from professional activity, removal from the profession or, in relevant circumstances, removal of sworn status.
We assist with chamber complaints, written defenses, documentary evidence, procedural issues, parallel client disputes and available administrative or judicial remedies. Statements made in a client dispute, tax investigation, disciplinary response or criminal proceeding should be coordinated because they may affect the other proceedings.
Partner and Shareholder Disputes in Accounting Firms
When relationships between founding partners deteriorate, professional regulation can make separation more complicated than an ordinary shareholder dispute. Typical issues include withdrawal, valuation, receivables, client allocation, client files, trade names, employee transfers, ongoing engagements, non-solicitation, confidentiality, regulatory notifications and access to accounting or audit records.
For regulated audit firms, any ownership or management restructuring must additionally be checked against KGK authorization conditions. A professional-firm separation should be approached as both a corporate dispute and a regulatory transition.
Frequently Asked Questions About Accounting Law in Türkiye
What law regulates accountants and accounting firms in Turkey?
The principal legislation governing professional accountants in Turkey is Law No. 3568 on Certified Public Accountancy and Sworn-in Certified Public Accountancy (Serbest Muhasebeci Mali Müşavirlik ve Yeminli Mali Müşavirlik Kanunu). It regulates the SMMM and YMM professions, including professional qualifications, permitted activities, professional organization and professional responsibilities. Depending on their activities, accounting firms may also be subject to Tax Procedure Law No. 213, the Turkish Commercial Code, anti-money laundering legislation, the Personal Data Protection Law No. 6698 and, for independent audit activities, the KGK independent audit framework.
Who regulates accounting firms in Turkey?
Accounting firms in Turkey may be supervised by several authorities depending on the services they provide. TÜRMOB and the relevant SMMM or YMM Chambers form the principal professional regulatory structure under Law No. 3568. The Revenue Administration (GİB) is relevant to tax declarations and tax procedures; the Public Oversight, Accounting and Auditing Standards Authority (KGK) regulates authorized independent auditors and audit firms; MASAK supervises applicable anti-money laundering obligations; and the Personal Data Protection Authority oversees compliance with the KVKK.
Can a foreign accounting firm provide accounting services in Turkey?
A foreign accounting firm cannot assume that establishing an ordinary Turkish company automatically authorizes it to perform regulated SMMM or YMM activities. Professional accounting services falling within the scope of Law No. 3568 are subject to profession-specific qualification and authorization requirements. Article 8 of Law No. 3568 also contains a specific regime concerning foreign certified public accountants and applies a reciprocity-based framework. Accordingly, the Turkish corporate structure and the professional authorization of the individuals performing regulated accounting services should be assessed separately. If independent audit services will also be provided, KGK requirements must additionally be considered.
Does an accounting firm need KGK authorization in Turkey?
Not every accounting firm requires KGK authorization. KGK authorization becomes relevant where the firm intends to operate as an independent audit organization within Turkey’s regulated independent audit framework.
KGK requires an independent audit organization to satisfy specific conditions concerning its corporate form, share structure, business purpose, professional ownership, auditors, responsible auditors, management structure and quality-control systems. For example, KGK states that an audit organization must be a capital company, its shares must be registered, all shareholders must be professional members, and more than half of its capital and voting rights must belong to its auditors.
How can an independent audit firm obtain authorization in Turkey?
An independent audit firm must apply to the Public Oversight, Accounting and Auditing Standards Authority (KGK) and demonstrate compliance with the authorization requirements under the Independent Audit Regulation.
The application begins through KGK’s Audit Organizations Authorization and Information Entry System. The applicant uploads documents demonstrating that the requirements are satisfied, after which KGK reviews the application and submits the completed file for the relevant decision. According to KGK’s published procedure, an organization approved for authorization must pay the applicable fees and request registration and publication within 90 days in order to be entered into the official register as an authorized independent audit organization.
Are accountants subject to MASAK and anti-money laundering rules in Turkey?
Yes, certain accounting professionals are expressly treated as obliged parties under Turkey’s anti-money laundering regime. MASAK lists independent accountants, SMMM professionals and YMM professionals working without being attached to an employer among the obliged parties. Independent audit organizations authorized to audit financial markets are also included within the relevant framework.
The principal statutory framework includes Law No. 5549 on Prevention of Laundering Proceeds of Crime and its secondary regulations. Depending on the circumstances, obligations may include customer identification, beneficial-owner checks, suspicious transaction assessment, suspicious transaction reporting and recordkeeping. MASAK also publishes sector-specific suspicious transaction reporting guidance for accounting professionals.
Can an accountant be liable for a client’s tax penalties in Turkey?
Potentially yes, but liability is not automatic simply because the client receives a tax assessment or penalty. The accountant’s statutory role, the relevant declaration or certification, the information supplied by the client and the nature of the error must be examined.
Under Repeated Article 227 of Tax Procedure Law No. 213, professionals authorized under Law No. 3568 may bear responsibility in relation to declarations they sign where the information contained in those declarations is inconsistent with the underlying accounting records and supporting documents, within the limits of the applicable statutory regime. Professional responsibility may therefore extend beyond an ordinary contractual relationship in certain tax matters.
For this reason, accounting firms should clearly document the information received from clients, missing documentation, warnings given and the precise scope of the professional engagement.
What should an accounting firm’s client agreement include in Turkey?
An accounting firm’s client agreement should clearly define what the accountant is responsible for and what remains the client’s responsibility. This is particularly important where the accountant prepares records, submits tax declarations, processes payroll or accesses the client’s electronic tax systems.
The agreement should address the scope of professional services, documents and information to be supplied by the client, filing responsibilities, deadlines, professional fees, additional services, confidentiality, personal data processing, termination, transfer of records and liability allocation. The professional rules are particularly important because TÜRMOB regulations contemplate written professional service agreements, while specific electronic tax filing activities may also involve Electronic Declaration Intermediation and Responsibility Agreements with taxpayers. Applicable professional fees should additionally comply with the relevant minimum fee rules.
Does KVKK apply to accounting firms in Turkey?
Yes. Accounting firms processing personal data are subject to Law No. 6698 on the Protection of Personal Data (KVKK) where its statutory requirements apply. This is particularly relevant because accounting businesses routinely process information concerning clients, employees, shareholders, directors and other individuals.
Payroll records, identification information, bank details, salary information, employee records and other financial documents may contain personal data. Accounting firms should therefore assess the applicable legal basis for processing, privacy notices, data security, retention practices, access controls, processor relationships and data-subject rights. International accounting networks must also consider the separate rules governing transfers of personal data outside Turkey under Article 9 of the KVKK.
How are accounting firm partner disputes handled in Turkey?
Accounting firm partner disputes may involve both ordinary corporate law and profession-specific accounting regulations. The applicable approach therefore depends on whether the practice operates as a professional partnership office, a professional company or an authorized independent audit organization.
Typical disputes may concern withdrawal of a partner, share transfers, management rights, unpaid receivables, allocation of clients, use of the firm’s name, professional files and ongoing engagements. TÜRMOB’s professional rules specifically regulate accounting professionals operating through partnership offices and professional companies. Where the business is also an authorized independent audit organization, any proposed ownership or management change must additionally remain compatible with KGK requirements concerning professional ownership, voting rights, management and auditor composition.
For this reason, a partner exit or restructuring should be reviewed not only as a shareholder dispute but also as a professional regulatory issue.
Legal Counsel Built Around the Accounting Profession
Accounting firms advise businesses on compliance while carrying their own substantial regulatory responsibilities. A commercial disagreement can become a professional liability claim; a client-document issue can become a tax investigation; an internal compliance failure can become a MASAK or KVKK matter; and a partner exit can affect professional authorization.
Turkish Trade Lawyers advises accounting and audit professionals on regulatory, contractual, corporate and dispute-resolution matters arising from their operations in Türkiye.
