As is known, the Communiqué published in the Official Gazette dated 14.02.2025 required certain companies to maintain electronically the share ledger, the board of directors’ resolution book, the board of managers’ resolution book, and the general assembly meeting and negotiation book. However, with the Communiqué published in the Official Gazette dated 22.09.2025 and numbered 33023, one of the most debated issues among companies under the Electronic Commercial Book System (“ETDS”), namely the obligation to keep the board of directors’ resolution book electronically, has been abolished.

Accordingly, companies that have already started to maintain their board of directors’ resolution book electronically but wish to revert to the physical book system pursuant to the amendment to the Communiqué may apply to the Ministry of Trade until 01.01.2026 to close their electronic books and subsequently apply to a notary public to open their physical books.

Applications to the Ministry of Trade may be submitted through the following channels, as stipulated in the Communiqué:

• ViaKEP (Registered Electronic Mail) to ticaretbakanligi@hs01.kep.tr,
• Bypost to Söğütözü Mah. 2176. Sk. No:63, 06530, Çankaya/Ankara,
• Through thee-Government system,
• Or by direct application to the same address within the framework of the Law No. 3071 on the Exercise of the Right to Petition.

Ensuring that applications are made in due time and in compliance with procedural requirements is of critical importance in order to avoid potential risks regarding invalidity, evidentiary value, and administrative sanctions. Therefore, it is recommended that companies adopt resolutions in line with their internal procedures, update authorizations, complete application files properly, and carry out the process in accordance with the applicable legislation.

Best regards,
DT Law