Information Note on the Implementation Instruction Regarding the Communiqué on Supporting the Conversion of Firms’ Foreign Exchange Sourced from Abroad into Turkish Lira

On 1 October 2026 the Central Bank of the Republic of Türkiye (CBRT) put into effect the new Implementation Instruction regarding the Communiqué No. 2023/5 on Supporting the Conversion of Firms’ Foreign Exchange Sourced from Abroad into Turkish Lira. With the new Instruction, the previous implementation instruction dated 26 January 2023 was repealed; the conditions for benefiting from the support, firm-based limits, bank controls and the consequences attached to irregular use have been re-regulated. The new framework is of significant importance for the financial planning and internal control processes of exporters and firms providing foreign exchange earning services.

As is known, under the Communiqué published in Official Gazette No. 33327 on 1 August 2026, the base rate of foreign exchange conversion support was determined as 2%, whilst the period of the 3% support payment, previously implemented on a temporary basis, had been extended until 31 January 2027.

Scope of Support and Eligible Firms

Legal entity firms legally resident in Türkiye, excluding banks and other financial institutions determined by the CBRT, may benefit from the support. The scope encompasses foreign currency export revenues from goods, foreign exchange earning service revenues obtained from non-residents (including services provided to foreigners within Türkiye) and foreign exchange obtained by free zone firms exclusively from sales made abroad. Foreign exchange arising from the export of relevant precious metals has been excluded from the scope (Instruction Article 3).

In support transactions, US dollars, euros or British pounds sterling are sold to the CBRT. Other foreign currencies traded by the CBRT may be converted into one of these three currencies by the intermediary bank and sold. The support amount is determined by applying the applicable support rate to the Turkish lira amount calculated on the basis of the foreign exchange buying rate announced by the CBRT at 11am on the transaction date (Articles 4 and 5/1).

New Support Ceiling and Firm Sales Limit

The maximum foreign exchange conversion support that each firm can benefit from in a calendar year has been determined as TL 100 million (Article 5/5). In addition, the Turkish lira equivalent of the foreign exchange that can be sold to the CBRT within the scope of support is capped by a separate firm sales limit calculated by the CBRT based on the firm’s operating profit and 12-month labour costs. If the firm operates at a loss, only labour costs are taken as the basis in the calculation. Sales limits are updated, as a rule, in January and July; unused limits do not roll over to the subsequent calendar year (Article 6).

For the period from 1 October to 31 December 2026, a coefficient of 0.25 will apply to both the firm sales limit and the TL 100 million maximum support amount, with the support ceiling being TL 25 million for this 3-month period. Foreign exchange sales and support utilised prior to 1 October 2026 are not included in the calculation of the remaining limit for this period (Provisional Article 4).

Application Conditions, Foreign Exchange Position and Timeframes

When selling foreign exchange, firms must submit a support request form to the intermediary bank, together with a foreign exchange position notification form prepared by an independent accountant and financial advisor (SMMM) or sworn-in certified public accountant (YMM) and endorsed jointly with the firm. Firms whose foreign exchange position ratio exceeds 10% cannot benefit from the support. The notification form is valid for 15 days from the date of issuance and may be used for multiple transactions within this period. The certificate of activity of the professional who approved the form must also be submitted to the bank (Articles 5/4 and 7/1).

Whilst the relevant Export Value Acceptance Certificate (İBKB) and customs declaration requirements are sought for goods export proceeds, foreign exchange earning service revenues must be sold to the CBRT within 180 days of the definitive invoice date, and overseas sales revenues of free zone firms within 180 days of the date on which the relevant Free Zone Transaction Form is approved. For advance export proceeds, support may be requested at the time of sale; however, support will not be disbursed unless customs declaration data bearing the phrase ‘Advance Payment’ corresponding to at least the amount sold, together with the foreign exchange position notification form, is submitted within 6 months following the sale (Articles 5/1 and 5/9).

Special Transactions and Intermediary Bank Controls

In indirect (intermediated) exports, support may be disbursed directly to the supplier or manufacturer firm, provided that the requisite declaration, contract, customs declaration and invoice documents are submitted. Firms intermediating foreign exchange earning services, on the other hand, may benefit from the support solely over the intermediation service fee to which they are entitled. In exports within the scope of the Inward Processing Regime, the value of imports without payment is deducted from the export value when determining the support tax base (Articles 5/6, 5/11 and 5/12).

Intermediary banks verify that the foreign exchange originates from abroad and that the transaction complies with the underlying documentation. It is required that the account balance did not fall below the relevant proceeds during the period between the date the export proceeds were credited to the account and the support request, and that the balance was not supplemented with non-export foreign exchange. Foreign exchange sold to the CBRT is non-refundable. Intermediary banks may collect a commission of up to a maximum of 1% of the support amount disbursed to firms (Articles 5/3, 7/2–3 and 7/14).

Financial and Administrative Consequences of Irregular Use

If it is determined that the support was used irregularly, contrary to its purpose or with inaccurate information and documentation, the support amount disbursed is recalculated on the basis of the exchange rate comparison stipulated in the Instruction; it is clawed back with interest calculated over the highest overnight lending rate announced by the CBRT on the determination date from the date of the foreign exchange sale until the date of determination, alongside Banking and Insurance Transaction Tax (Article 8/1).

Support and CBRT-sourced loan applications, as well as utilisation requests, of a firm found to be in violation will be rejected immediately. Applications will not be accepted for 1 year upon the first determination and for 3 years upon subsequent determinations, starting from the payment of the refund amount. Until the payment is made, the application restriction also applies to other firms controlled by the firm, controlling the firm or under common control. The CBRT may decide to file a criminal complaint (Articles 8/2–4).

Nevertheless, if the total support utilised within the scope of the determination does not exceed TL 100,000, the 1- and 3-year time restrictions do not apply, provided that the calculated refund amount is paid. The authority of the CBRT to take a separate decision on application restriction by evaluating the nature of the breach and other conditions remains reserved (Articles 8/7–8).

Transitional Provisions and Prior Transactions

In the event of a breach of foreign exchange non-acquisition commitments made prior to 1 October 2026 and in support transactions regarding advance export proceeds sold to the CBRT before this date, the provisions of the repealed Instruction will continue to apply. Determinations of irregularity made under the previous Instruction are not included in the recidivism calculation of subsequent determinations to be made under the new Instruction (Provisional Articles 1–3).

Evaluation

The new regulation conditions eligibility for the support not merely on the sale of foreign exchange to the CBRT, but on the firm’s financial data, foreign exchange position and the continuous documentation of the transaction’s origin. Within this framework, it is vital that firms verify their available sales and support limits prior to requesting support and evaluate timeframes relating to export and service revenues, bank account movements and supporting documents together. Especially in light of the refunds, interest and application restrictions extending to group companies that are tied to irregular use, it is recommended that internal control and record-keeping systems be reviewed prior to application.

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