Electronic invoice in Türkiye

A comprehensive guide to Türkiye’s centralized e-invoicing ecosystem: navigating GİB’s e-Fatura and e-Arşiv mandates, strict UBL-TR 1.2.1 compliance, and the critical need for authorized local integrators.

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Overview

Türkiye runs a mature ecosystem of electronic tax documents administered by Gelir İdaresi Başkanlığı (GİB), the Turkish tax administration. Two documents carry almost everything: e-Fatura, the structured invoice exchanged between registered participants through GİB's central infrastructure, and e-Arşiv Fatura, the electronic invoice for buyers who are not registered in e-Fatura — most B2C and a large part of cross-border.

The model is a centralised, clearance-like exchange, not Peppol four-corner. Every e-Fatura passes through GİB's central system. e-Arşiv works differently: daily reporting to GİB by the end of the following day, rather than prior clearance of each transaction. Which of the two applies depends not on the transaction but on whether both parties are registered.

UBL-TR 1.2.1

the national format — UBL-based, but not EN 16931 and not Peppol BIS

TRY 3 million

the general turnover threshold for e-Fatura — TRY 500,000 for some activities

5 years

the general retention period under the Tax Procedure Law

Timeline

Sixteen years of steady tightening, and the thresholds are now disappearing rather than falling.

Already in force

2010 — 2013

The legal foundation and the first mandatory wave

General Communiqué VUK No. 397 of 5 March 2010 created e-Fatura and the connection methods. Communiqué No. 421 of 14 December 2012 introduced obligation for the first taxpayer categories and provided for private integrators. From 1 September 2013 registered participants in the first wave had to send and receive e-Fatura in their mutual transactions.

1 July 2017

Export e-Fatura

A dedicated e-Fatura process was introduced for exports of goods and for passenger-accompanied export transactions. See Export and import.

1 January 2020

e-Fatura users move to e-Arşiv as well

Participants in e-Fatura also had to use e-Arşiv for invoices to buyers not registered in e-Fatura — the pairing that still defines the system.

1 January 2025

The TRY 3,000 rule

Taxpayers not yet connected to e-Arşiv had to create invoices above TRY 3,000 including taxes through the state portal or an authorised integrator.

1 January 2026

e-Arşiv regardless of amount

For most taxpayers, any invoice that is not an e-Fatura must now be issued as an e-Arşiv — with no amount threshold at all. The TRY 3,000 floor has gone.

Still ahead

1 January 2027

The deferred category follows

The no-threshold e-Arşiv rule extends to taxpayers under the simplified commercial profit regime and those keeping records on the işletme hesabı basis. Until the end of 2026 the TRY 3,000 threshold still applies to them — the one group for whom the old rule survives.

Who is in scope

Whether you must participate in e-Fatura directly depends on the status of both the seller and the buyer, not on the transaction:

—If both parties are registered in GİB e-Fatura, the invoice must be an e-Fatura

—If the seller uses e-Fatura or e-Arşiv but the buyer is not registered in e-Fatura, the seller issues an e-Arşiv

—Voluntary registration below the thresholds is permitted

—GİB may individually oblige a taxpayer to connect regardless of turnover or sector — for example following a tax risk analysis

The thresholds

GeneralTRY 3 million annual turnover for the relevant reporting period, applied from the 2022 reporting year

TRY 500,000For internet sales, and for trade in real estate and vehicles

No thresholdCertain sectors are in regardless of turnover

When the obligation starts

Transition happens from the beginning of the seventh month of the year following the period in which the threshold was exceeded — in practice usually 1 July of the following year. That gives a useful lead time, but it also means the trigger event is a set of accounts filed long before the deadline appears on anyone's calendar.

Beyond the turnover test, obligation extends to defined sectors and activities: licensed energy and petroleum operations, certain excisable goods, electronic marketplaces, internet advertising, medical suppliers, hotels, trade in real estate and vehicles, charging network operators and other listed categories.

e-Fatura and e-Arşiv

e-Fatura — centralised exchange

01 The sender or its private integrator builds the UBL-TR document

02 It is transmitted to GİB's central system — the Merkez

03 GİB performs technical checks and routing

04 The document is delivered to the recipient's electronic mailbox (posta kutusu) or its integrator, with system and application responses returned

The 2026 guidance requires expressly that all e-Fatura pass through the GİB system, and an integrator that breaches this can have its authorisation cancelled. The presence of private integrators on both sides does not make the network decentralised — GİB remains the central node.

The precise classification is centralised exchange, clearance-like CTC, with the tax administration inside the mandatory transport path. It is neither Peppol four-corner nor Peppol-based five-corner. We prefer "clearance-like" to a bare "clearance" because GİB checks technical and structural correctness and ensures delivery — that should not be equated automatically with substantive tax approval of every transaction.

e-Arşiv — post-issuance reporting

—The invoice is created by the seller or its integrator

—An electronic or paper representation goes to the buyer

—Details are reported to GİB in e-Arşiv reports, signed with a financial seal or electronic signature and a timestamp

—Reporting is prepared for daily periods and must be transmitted by the end of the following day

That is post-issuance reporting, not prior clearance and not universal real-time transmission. Special exceptions exist — the SARJANLIK e-Arşiv type, tied to certain charging infrastructure transactions, must be transmitted to GİB immediately after issue.

B2G

There is no single universal B2G date comparable to the European model under Directive 2014/55/EU. Public institutions within the Public Financial Management and Control Law No. 5018 are connected under rules set by Muhasebat Genel Müdürlüğü within the integrated public financial management information system (BKMYBS).

Implementation has been phased. In September 2021 the Ministry of Finance reported that Kamu e-Fatura had been provided to 203 public administrations, and GİB publishes a separate Kamu e-Fatura Technical Guide.

For a specific public-sector supply, then, the question is practical rather than legal: is that institution connected, and what identifiers or budget references does it require? Where supplier and public body are both registered e-Fatura users, the same mandatory GİB route applies. Peppol is not a national mandatory channel for Turkish B2G.

B2C

A registered e-Fatura participant must issue an e-Arşiv Fatura to a consumer or any other unregistered recipient. The recipient may be given an electronic representation or a paper printout — but the electronic original is created and retained under GİB's rules. e-Arşiv has the same legal nature as an ordinary invoice; it is not a separate species of primary document.

A common misreading

The rule does not mean every retail purchase requires a full invoice. Where the legislation permits a fiscal cash register receipt (ÖKC receipt), that document continues to apply. e-Arşiv is required where the Tax Procedure Law says an invoice must be issued.

Internet sales carry extra requirements, including a dedicated invoice number sequence and specific internet-sale data fields — a detail that catches out e-commerce integrations built on the general template.

UBL-TR and formats

The national format is UBL-TR, currently version 1.2.1. The name is the trap: it is UBL-based, but it is not EN 16931, not Peppol BIS Billing and not interchangeable with either. A document that does not conform to GİB's mandatory formats is not recognised as a proper e-belge — an electronic document — at all.

For a single international product, at minimum a two-way conversion is required: EN 16931 / Peppol BIS ↔ UBL-TR 1.2.1. And the Turkish document must go through GİB regardless of any parallel Peppol exchange.

On PDF: where both parties are obliged to use e-Fatura, a paper invoice or a PDF-only document does not replace the mandatory e-Fatura. Where e-Arşiv applies, the buyer may legitimately receive an electronic representation or a printout — but the electronic original still exists and is retained under GİB's rules.

Peppol in Türkiye

Peppol is not a mandatory or principal domestic channel. No Turkish Peppol Authority appears in the published OpenPeppol list.

A foreign Peppol Access Point's certification does not by itself confer the right to serve the Turkish domestic e-Fatura market: that requires a separate GİB authorisation as an Özel Entegratör. Peppol can carry a parallel commercial document to a foreign counterparty — it cannot carry the Turkish tax document.

Export and import

Exporting goods

Since 1 July 2017, registered e-Fatura taxpayers must use the special export e-Fatura for exports of goods falling under Article 11 of the VAT Law and for certain transactions involving goods for foreign passengers. The document goes through GİB with a separate customs process. A visualisation, PDF, commercial UBL or Peppol BIS/EN 16931 invoice may additionally be given to the foreign buyer — none of which may substitute for the Turkish export e-Fatura.

Exporting services and other foreign customers

A foreign recipient is normally not registered in GİB e-Fatura, so the Turkish party generally issues an e-Arşiv Fatura unless the transaction falls within the special customs export e-Fatura process. A readable PDF may be sent to the buyer, but the Turkish tax original must comply with e-Arşiv and UBL-TR.

Importing into Türkiye

The invoice of a foreign supplier without Turkish tax registration remains a foreign document and does not pass through GİB e-Fatura. The Turkish buyer records the import and applies the customs and tax procedure documents. Where the foreign supplier operates through a Turkish permanent establishment or another local VAT registration and falls under the e-Fatura mandate, the ordinary Turkish rules apply to the local transaction.

ViDA

Türkiye is not an EU member state, so a supply from Türkiye to an EU buyer is an export and import operation, not an intra-EU supply. ViDA's 1 July 2030 digital reporting and the 1 January 2035 alignment deadline concern EU VAT transactions, not the Turkish domestic system. ViDA can reach a Turkish group where the transaction runs through an EU company or fixed establishment, where the Turkish company holds an EU VAT registration and performs a covered transaction, or where a European buyer or platform requires EN 16931 or ViDA-ready data. No official GİB plan to replace UBL-TR with EN 16931, adopt Peppol or join ViDA has been published.

Özel Entegratör

Serving the Turkish domestic market requires GİB authorisation as a private integrator (Özel Entegratör). An existing European Peppol Access Point certification cannot be used as the sole basis for a direct domestic service. Two market-entry models are realistic.

Partnership

The foreign provider supplies the client interface, ERP integration, Peppol and conversion; an authorised Turkish Özel Entegratör handles the GİB clearance and reporting, the financial seal (mali mühür) and local storage.

Own national authorisation

A suitable Turkish taxable structure is established or registered, local infrastructure is built, the ISO/TÜRKAK, information security, audit and testing requirements are met, and GİB authorisation is then applied for.

What an integrator risks

Consequences for an Özel Entegratör go well beyond money:

—Findings and remedial requirements following an audit

—Suspension or cancellation of the authorisation, and removal from the GİB list

—An obligation to notify clients that the authorisation has ended

—Migration of clients to another integrator, to the GİB Portal or to direct integration

One breach is named explicitly as grounds for cancelling the authorisation: transmitting an e-Fatura around the GİB Merkez. Any architecture that treats the central system as optional for performance or resilience reasons is a business-ending design.

Archiving

Turkish tax records are generally retained for five years under the Tax Procedure Law. Confirm the exact period for the specific documents and years with a Turkish adviser, since the limitation period drives the practical outer edge.

What is retained is the UBL-TR electronic original, not the printout given to the buyer — this applies to e-Arşiv just as much as to e-Fatura

For e-Arşiv the reports themselves belong in the archive — signed with the financial seal or electronic signature and timestamped, they are what evidences timely reporting

For e-Fatura, the system and application responses returned through the Merkez are part of the delivery evidence

Where a client uses an Özel Entegratör, local storage is typically part of the integrator's service — which makes the exit provisions of that contract an archiving question, not just a commercial one.

Penalties

Communiqué No. 509 applies the Tax Procedure Law penalties where a taxpayer fails to connect to e-Fatura in time, issues a paper invoice instead of a mandatory e-Fatura, fails to receive a mandatory e-Fatura, issues a paper invoice instead of a mandatory e-Arşiv, or uses a document that does not conform to GİB's technical formats.

The 2026 scale under Article 353 VUK

Minimum per documentTRY 3,400

First detectionTRY 17,000

Second / thirdTRY 35,000 / TRY 53,000

Fourth / fifthTRY 70,000 / TRY 87,000

Sixth and beyondTRY 170,000

Annual capTRY 17 million per document type

FloorNot less than 10% of the amount that should have been shown, or of the difference identified

The exact amount depends on the nature of the breach, the number of documents, the number of detections and the applicable version of the Tax Procedure Law. Treat these as the official 2026 limits and steps — not as a single fixed fine for any e-invoicing incident.

The consumer is exposed too. A final consumer who did not receive a mandatory invoice, receipt or other prescribed document faces, on the official 2026 table, a penalty of TRY 8,700 per violation with an annual cap of TRY 87,000.

VAT deduction

In the general sense, no — the e-Fatura is not a separate substantive condition of deduction. Turkish VAT law ties the right to deduct to VAT shown separately on an invoice or equivalent document and to that document being properly recorded in the mandatory books. The law does not frame the right exclusively through the term e-Fatura.

But the form of the document is decisive in practice. e-Arşiv has the same legal nature as a paper invoice. Where the parties are obliged to use e-Fatura, an ordinary paper invoice or a PDF-only file is an improper form. A document that does not conform to GİB's mandatory formats is not recognised as a proper e-belge at all.

So the electronic invoice is not a distinct legal condition of deduction for every transaction — but where e-Fatura or e-Arşiv is mandatory, complying with the required electronic form becomes the decisive factor in whether the deduction survives an audit unchallenged.

How we help

Türkiye is a partnership market with a real conversion layer — more of a European pipeline survives here than in most clearance countries, but none of it reaches GİB by itself:

Two-way conversion between EN 16931 / Peppol BIS and UBL-TR 1.2.1

Correct routing between e-Fatura and e-Arşiv based on the counterparty's registration status

Submission through an authorised Özel Entegratör, with system and application responses handled

e-Arşiv daily reporting by the end of the following day, and the immediate-transmission exceptions

Export e-Fatura with the customs process, and the dedicated internet-sales number sequence

The European profile the EU counterparty needs, alongside the Turkish document

Connection by API, SFTP and CSV, with ERP and IDoc source data

Frequently asked questions

Is e-invoicing mandatory in Türkiye?

Very largely. The general e-Fatura threshold is TRY 3 million annual turnover from the 2022 reporting year, with TRY 500,000 for internet sales and trade in real estate and vehicles, and no threshold at all for certain sectors. Since 1 January 2026 most taxpayers must issue any non-e-Fatura invoice as an e-Arşiv regardless of amount. The deferred category — the simplified commercial profit regime and işletme hesabı taxpayers — follows on 1 January 2027, keeping the TRY 3,000 threshold until then.

e-Fatura or e-Arşiv — how do I know which?

By the counterparty's registration status, not the transaction. If both parties are registered in GİB e-Fatura, the invoice must be an e-Fatura. If you use e-Fatura or e-Arşiv but the buyer is not registered in e-Fatura, you issue an e-Arşiv. That is why routing logic based on a live check of the recipient's registration is the core of any Turkish integration — and why a foreign customer normally receives an e-Arşiv unless the special customs export e-Fatura process applies.

Does GİB approve the invoice before it reaches the buyer?

For e-Fatura, GİB is in the mandatory transport path: the document goes to the central Merkez, which performs technical checks and routes it to the recipient's mailbox. We describe this as clearance-like rather than clearance, because GİB checks technical and structural correctness and ensures delivery rather than substantively approving each transaction. e-Arşiv is different — the invoice goes to the buyer first, and details are reported to GİB in daily e-Arşiv reports by the end of the following day.

Can I use my European Peppol Access Point?

Not for the domestic market. Peppol is not a mandatory or principal domestic channel, no Turkish Peppol Authority appears in the OpenPeppol list, and Access Point certification confers no right to serve Turkish domestic e-Fatura — that needs separate GİB authorisation as an Özel Entegratör. The realistic routes are partnership with an authorised Turkish integrator, or establishing a Turkish structure and meeting the ISO/TÜRKAK, information security, audit and testing requirements before applying.

UBL-TR is UBL — will my EN 16931 invoice work?

No. UBL-TR 1.2.1 is UBL-based but is not EN 16931 and not Peppol BIS Billing, and a document that does not conform to GİB's mandatory formats is not recognised as a proper e-belge at all. A single international product needs at minimum two-way conversion between EN 16931 / Peppol BIS and UBL-TR 1.2.1 — and the Turkish document must go through GİB regardless of any parallel Peppol exchange. No official plan to replace UBL-TR with EN 16931 or adopt Peppol has been published.

Can I send a PDF instead?

Where both parties are obliged to use e-Fatura, no — a paper invoice or PDF-only document does not replace the mandatory e-Fatura. Where e-Arşiv applies, the buyer may receive an electronic representation or a paper printout quite legitimately, but the electronic original is created and retained under GİB's rules. On exports you may additionally give the foreign buyer a visualisation, PDF, commercial UBL or Peppol BIS invoice — never in place of the Turkish export e-Fatura.

What are the penalties?

On the official 2026 table under Article 353 of the Tax Procedure Law, the minimum is TRY 3,400 per document, rising through TRY 17,000 on first detection to TRY 35,000, 53,000, 70,000, 87,000 and TRY 170,000 from the sixth detection, with an annual cap of TRY 17 million per document type and a floor of 10% of the amount that should have been shown. A final consumer who did not receive a mandatory document faces TRY 8,700 per violation, capped at TRY 87,000 a year. The exact amount depends on the breach, the number of documents and detections and the applicable version of the law.

What can cost an integrator its authorisation?

Transmitting an e-Fatura around the GİB Merkez is named explicitly as grounds for cancellation — the 2026 guidance requires all e-Fatura to pass through the GİB system. Beyond that, an Özel Entegratör faces audit findings and remedial requirements, suspension or cancellation of the authorisation, removal from the GİB list, an obligation to notify clients, and migration of those clients to another integrator, the GİB Portal or direct integration. Any design that treats the central system as bypassable is a business-ending one.

Summary

Türkiye is a centralised, clearance-like market built on two paired documents. e-Fatura moves between registered participants through GİB's Merkez, which is in the mandatory transport path; e-Arşiv covers everyone else and is reported daily, by the end of the following day. Which applies is decided by the counterparty's registration status, which makes live routing logic the core of any integration.

The thresholds are no longer just falling — they are disappearing. Since 1 January 2026 most taxpayers must issue e-Arşiv regardless of amount, with the deferred category following on 1 January 2027. The general e-Fatura entry threshold remains TRY 3 million, TRY 500,000 for internet sales and property and vehicle trade, and nothing at all for listed sectors.

For a European provider the name UBL-TR is the trap and the opportunity in one. More of a European pipeline survives here than in Brazil or Mexico, but UBL-TR 1.2.1 is not EN 16931 and not Peppol BIS, a non-conforming document is not an e-belge at all, and the Turkish original must pass through GİB whatever else you send. Plan for two-way conversion plus an authorised Özel Entegratör — and never design around the Merkez.

Resources

GİB e-Belge portal The official hub for e-Fatura and e-Arşiv — technical guides, the UBL-TR packages and the registered user list Gelir İdaresi Başkanlığı (GİB) The tax administration — communiqués, the penalty tables and the announcements that move the thresholds e-Fatura Portal The state portal route, and the option a client falls back on if an integrator's authorisation ends e-Belge — technical guides and integrator list Where the Kamu e-Fatura technical guide and the list of authorised Özel Entegratör providers are published Resmî Gazete The official gazette — where Communiqué No. 509 and any amendment to the thresholds is published first

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