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Special Reporting Requirements Introduced For Foreign Currency Borrowings


The Central Bank of the Republic of Turkey’s (“CBRT” or the “Central Bank”) establishing legislation was amended in November 2017 to provide broad information gathering powers to the Central Bank on the foreign currency positions of individuals and corporations.

Under this authority, the Central Bank has issued the Regulation on the Principles and Procedures of the Supervision of the Central Bank of the Republic of Turkey on Transactions Affecting the Foreign Currency Position (the “Regulation”) which was published in the Official Gazette numbered 30335 and dated 17 February 2018. The Regulation introduces special reporting requirements in respect of foreign currency and currency-indexed borrowings of USD15 million or above.

The changes appear complementary to the recently issued foreign currency borrowing limitations under Decree No. 32, scheduled to enter into force as of May, which offer a higher degree of borrowing freedom to corporations with existing foreign currency borrowings of USD15 million.

Reporting thresholds

According to the Regulation, companies with outstanding foreign currency and currency-indexed cash borrowings equal to or greater than USD15 million as of the last day of an accounting period as determined according to their TAS (Turkish Accounting Standards) financial statements or, if these are not available, tax financials, will be required to report their foreign currency positions to the Central Bank on a quarterly basis.

The dollar equivalent of the amount of any borrowings denominated in a different currency will be calculated on the basis of the buying rates published in the Official Gazette on the last business day of the relevant accounting period.

Note that banks and financial institutions are exempt from reporting requirements.

Reporting requirements

A standard reporting form to be provided by the Central Bank will need to be filed through an online platform accessible at “” and signed by electronic signature on behalf of the relevant company.

Reporting periods are as follows:

  • for interim accounting periods ending on 31 March, 30 June and 30 September, by the end of the immediately following month;
  • for annual accounting periods ending on 31 December, by the end of the following third month.

Independent audit requirements

The Regulation requires that annual reports submitted to the system be audited by an independent audit firm or an individual independent auditor by the end of May of each year. Article 5 of the Regulation requires companies to appoint independent auditors within 60 days from the date they become subject to reporting requirements.


Failure to comply with reporting obligations and any misleading information may prompt sanctions under Central Bank’s establishing legislation which include judicial fines.

The Central Bank may also report any auditors who “verify” incomplete or incorrect information to the Public Oversight Accounting and Auditing Standards Authority.

Effective time

The Regulation does not provide any transition periods and has become effective as of its publication on 17 February 2018. Companies which exceed the borrowing thresholds should take steps to put appropriate arrangements in place with respect to any reporting and audit requirements under the Regulation.



Murat Soylu

Can Özilhan

Zeki Nizam Cebe