From Courtroom to Statute Book: Türkiye Rebuilds Its Tax E-Notification Framework

A constitutional challenge, a nine-month countdown and a sweeping legislative response — Türkiye’s tax e-notification regime has undergone a fundamental transformation. On 24 June 2026, the Turkish Grand National Assembly adopted Law No. 7587 (the “Law”), published in the Official Gazette on 1 July 2026 and effective the same day. The Law rewrites the electronic notification (“e-notification”) regime under Article 107/A of the Turkish Tax Procedure Law (“TPL”), replacing a patchwork of secondary regulation with a comprehensive statutory framework governing mandatory participation, exemptions and removal from the system.

Following the Constitutional Court’s 15 January 2026 decision (E. 2025/94, K. 2026/11), the Court held that the essential elements of the e-notification obligation must be laid down in primary legislation and annulled the specific wording in the third paragraph of the former Article 107/A that empowered the Ministry of Treasury and Finance to “impose the obligation to use an electronic address suitable for notification and to determine the persons to whom electronic notification would be made”. The decision was published in the Official Gazette before Law No. 7587 took effect, but the annulment was deferred for nine months from publication. Before that period expired, the legislator enacted Law No. 7587, replacing Article 107/A in its entirety and moving key aspects of the e-notification regime from secondary legislation into the TPL, thereby strengthening its statutory basis.

Who Must Now Use E-Notification — And Why It Matters

Until now, much of the heavy lifting was done by ministerial communiqués and administrative guidance. That era is over. As of 1 July 2026, the statute itself spells out which taxpayers must participate in the e-notification system:

• Corporate income taxpayers;
• Income taxpayers whose commercial, agricultural or professional income is taxed on actual (real) basis;
• Collective partnerships and ordinary limited partnerships; and
• Natural persons, legal entities and entities without legal personality in whose name goods subject to registration under List (II) annexed to the Special Consumption Tax Law are first registered, including motor vehicles such as passenger cars, motorcycles, buses, minibuses and certain commercial vehicles.

These statutory anchors bring welcome certainty. The deemed-service rule — long a flashpoint in tax litigation — is likewise elevated to statute: an electronic notification is deemed served at the end of the fifth day following the date on which the notification is transmitted to the recipient through the system, with litigation and other deadlines running from that point.

Opening the Door — And Carving Out an Exception Participation is not a one-way street. The amended Article 107/A formalises the right of taxpayers who fall outside the mandatory categories to join the e-notification system voluntarily.

More striking is a brand-new exemption: individuals with a certified disability rate of 90% or more are now expressly excluded from the mandatory e-notification obligation. Embedded directly in the TPL, this carve-out will matter most in practice for vehicle acquisitions and similar transactions that would otherwise trigger e-notification duties.

This is not a minor refinement. For the first time, the statute itself recognises a ground for exemption that had no foothold in the previous wording of Article 107/A.

The amended law also narrows the Ministry’s delegated regulatory authority: under the new third paragraph of Article 107/A, the Ministry of Treasury and Finance retains authority to establish or use the technical infrastructure for electronic notification and to determine procedural and implementational matters relating to the article’s application, but can no longer define by regulation who must participate in the e-notification system, as this is now set out directly in the statute.

Five Ways Out — And a Five-Year Tail

The amended law introduces five statutory removal categories: (i) legal entities registered with the trade registry are removed when their trade registry records are deleted, while other legal entities are removed when the records in their respective registries are deleted; (ii) natural persons are removed upon death or when declared legally absent; (iii) natural persons subject to mandatory e-notification may be removed only after the end of the fifth calendar year following the date on which their tax liability ends, upon request and provided no other condition requiring mandatory participation applies; (iv) voluntary participants may be removed upon request, taking the request date into account, provided no other condition requiring mandatory participation applies; and (v) persons aged 65 or above may be removed upon request, taking the request date into account.

For natural persons subject to mandatory e-notification, removal is only possible after the end of the fifth calendar year following the cessation of their tax liability, provided they submit a request and no other mandatory-use criteria apply. Consequently, former sole traders and professionals may remain subject to valid electronic service for several years after ceasing their activities and should continue monitoring their e-notification accounts during this period.

A Safety Valve for Older Taxpayers

Recognising that digital obligations can weigh disproportionately on older individuals, the amended Article 107/A allows anyone aged 65 or above to leave the e-notification system simply by submitting a request — no further conditions attached.

No Reset Required: Transitional Continuity

Businesses already enrolled can breathe easy. Under newly introduced Provisional Article 38, taxpayers registered in the e-notification system before 1 July 2026 carry over automatically — no fresh application, no re-registration, no gap in coverage.

What Businesses Should Do Now

The new framework trades regulatory ambiguity for statutory clarity, but that clarity demands action. Businesses should consider the following steps:

• Continue monitoring e-notification accounts, even after business activities have ceased.
• Update offboarding and tax-closure procedures to reflect the new five-year post-cessation rule.
• Incorporate checks for mandatory e-notification participation and disability exemptions into vehicle registration processes.
• Ensure clear internal responsibility for monitoring electronic notifications.
• Monitor future guidance and secondary legislation implementing the amendments.

A word of caution for former sole proprietors and professionals: electronic notifications may continue to land in your inbox — with full legal effect — for years after your tax liability has ended. Treat the e-notification account as the last thing you decommission, not the first.

The Bottom Line

Law No. 7587 does more than patch a constitutional gap — it modernises the foundations of Türkiye’s tax e-notification regime. By writing mandatory participation, exemptions, removal rules and transitional safeguards directly into primary legislation, and by reining in the Ministry’s delegated powers, the amendments deliver the legal certainty that taxpayers and practitioners have long called for. Now is the time to review compliance procedures and ensure your organisation is ready.

For further information on the implications of these amendments for your business, please contact your CMS partner or local CMS experts: Dr. Döne Yalçın  or Erdinç Dalar