THE OBLIGATION TO COUNTER-EXAMINATION REPORTS
ELECTRONICALLY HAS BEEN POSTPONED TO 2027
With the Communiqué on the Electronic Submission of Counter-Examination Reports
Attached to Sworn-in Certified Public Accountant (CPA) Audit Reports (Serial No: 1),
published in the Official Gazette on December 24, 2025 by the Revenue Administration, the
procedures and principles regarding sworn-in CPAs who send audit reports electronically
also sending the counter-examination reports attached to these reports electronically were
determined.
Electronic Submission via Digital Tax Office
According to the aforementioned circular, counter-examination reports, which are annexes
to sworn-in CPA audit reports submitted electronically via the digital tax office system, will
also be prepared, approved, and sent electronically to the relevant tax office via the digital
tax office system.
Counter-examination reports prepared, approved, and sent electronically via the system by
sworn-in CPAs conducting counter-examinations will be accepted as a document signed
and sealed by the sworn-in CPAs conducting the counter-examinations. The answers given
regarding the counter-examination reports at the taxpayer's premises, which are created
and sent electronically via the digital tax office system for response by sworn-in CPAs, will
be accepted as a document signed by the taxpayer or their authorized representatives who
gave the answer. Regarding the aforementioned counter-examination reports, if the
taxpayer grants sub-user authorization, certified public accountants/public
accountants who have an agency and responsibility agreement with the taxpayer
may view and edit the counter-examination reports; however, the authority to approve
them will belong to the taxpayer or their legal representatives.
From the date when counter-examination reports are mandatorily submitted only
electronically, paper-based counter-examination reports cannot be submitted to tax
offices, and even if submitted, they will not be considered by tax offices as they have
no legal validity.
Electronic Submission Was Scheduled to Start on July 1, 2026, but Postponed to
January 1, 2027
With the regulation published in the Official Gazette on August 21, the mandatory electronic
submission date was postponed to January 1, 2027. This postponement is particularly
important for companies with full tax certification and sworn-in certified public
accountant counter-examination processes, providing additional time for necessary
preparations.
