Mandatory Electronic Commercial Ledger: A Legal Guide for Companies Established After January 1, 2026

For new ventures and investors stepping into the business world, tracking post-establishment legal obligations is just as crucial as the company incorporation processes. Especially with the digitalization of regulations, the mandatory electronic commercial ledger is at the top of the agenda for company executives. The e-ledger obligations of companies established on and after January 1, 2026, are subject to different rules under the frameworks of the Ministry of Trade and the Revenue Administration (GİB). As Esenyel Partners, providing strategic support to our clients in corporate compliance processes, we examine in detail the steps that companies established in 2026 must take regarding their electronic ledger processes in this article.

Obligations Under ETDS and the Ministry of Trade

According to the Electronic Commercial Ledger System (ETDS) communiqués of the Ministry of Trade, all commercial companies (Joint Stock, Limited, Collective, Commandite, and Cooperatives) registered as of January 1, 2026, must mandatorily keep certain ledgers related to their partnership structure and general assembly in an electronic environment.

The most current legal situation to consider here is as follows:

Important Note: In accordance with the legislative amendment that entered into force on September 20, 2025, the Board of Directors Resolution Ledger has been completely removed from the scope of the ETDS obligation. It is a legal obligation for companies to continue keeping this ledger physically by having it notarized.

e-Ledger (Journal and General Ledger) Obligation Under GİB

The fact that a company is newly established in 2026 does not directly oblige it to keep an accounting-focused 2026 e-ledger (Journal and General Ledger) in the GİB system the very next day. To fall under the scope of the e-ledger, newly established companies must meet or opt for one of the following criteria:

• e-Invoice Chain Rule: All companies keeping ledgers on a balance sheet basis that optionally (voluntarily) transition to the e-Invoice application for operational speed or commercial prestige are also required to transition to the e-Ledger application.
• General Gross Revenue Limits: An obligation to join the system arises for taxpayers whose gross sales revenue exceeds the legal limits. For a new company registered in 2026, this general revenue criterion is evaluated at the end of its first accounting period.
• Sectoral Obligations: Businesses operating in specific sectors such as e-commerce, real estate construction/trading, and motor vehicle trading fall under the e-ledger transition requirements within the subsequent legal periods if they exceed the specified gross revenue limits.

Step-by-Step Requirements for Newly Established Companies

To avoid administrative sanctions, it is highly recommended that companies registered after January 1, 2026, strictly execute the following post-incorporation checklist:

• Determining Certificate Upload Periods: Businesses that are or will be included in the GİB e-Ledger system must clarify their e-ledger certificate upload preferences through their financial advisors via GİB portals within the legal timeframe.
• ETDS Activation via MERSİS: The moment the company incorporation is registered, the Share Ledger and General Assembly Ledger are automatically generated within the ETDS infrastructure. Company officials must log into this system and begin maintaining their legal records digitally.
• Procurement of Financial Seal and e-Signature: A Financial Seal belonging to the company or an e-Signature belonging to the authorized representatives must be obtained immediately to log into the MERSİS and ETDS systems, approve legal ledger notifications, and fulfill any future GİB e-Ledger/e-Invoice obligations.

Put Your Company’s Future on Solid Foundations

The mandatory electronic commercial ledger is a critical process that must be meticulously managed right from the establishment phase of companies; missing or incorrect practices can lead to heavy administrative fines. It is of great importance to seek professional support to ensure your company fully complies with current legislation, to execute MERSİS/ETDS integrations properly, and to proactively eliminate potential legal risks. To get more detailed information on the subject, secure your legal processes, and benefit from corporate legal consultancy services tailored to your company’s needs, you can contact the expert legal team at Esenyel Partners.