The procedures and principles regarding the implementation of the electronic notification system have been revised with the General Communiqué No. 596 of the Tax Procedure Law, published in the Official Gazette dated October 11, 2026, and numbered 33397.

This regulation sets out the implementation principles for the amendments made to Article 107/A of the Tax Procedure Law No. 213 by Law No. 7587, and repeals General Communiqué No. 456 of the Tax Procedure Law, which has been in effect since 2015.

The new regulation details the obligation to participate in the electronic notification system, application deadlines, taxpayers excluded from its scope, the legal consequences of electronic notification, and the conditions for exiting the system. Particularly noteworthy are the continuation of the electronic notification obligation after the termination of tax liability and the provision allowing individuals over 65 to exit the system.

Why was a new regulation needed in the Electronic Notification System?

Article 107/A of the Tax Procedure Law regulates the fundamental provisions regarding the electronic delivery of documents that the tax administration is required to notify taxpayers. Following its decision on January 15, 2026, the Constitutional Court deemed certain powers granted to the Ministry of Treasury and Finance regarding electronic notifications to be unconstitutional in terms of the principle of legality, and therefore annulled the relevant provisions. After this decision, Article 107/A of the Tax Procedure Law was revised by Law No. 7587, and the fundamental provisions of the electronic notification system were brought within a legal framework.

General Circular No. 596 specifies the details regarding the implementation of the aforementioned legal regulation. In this respect, the new Circular is not merely a technical regulation updating the existing electronic notification system, but an important regulation concerning the legal basis and operation of the system.

Who is required to participate in the Electronic Notification System?

Article 5 of Circular No. 596 specifies the individuals and organizations required to use the electronic notification system. Accordingly, the following groups are obliged to participate in the electronic notification system, subject to the exceptions specified in the Circular:

• Corporate tax payers,

• Income tax payers who are taxed under the real method due to their commercial, agricultural and professional earnings,

• Collective companies and limited partnerships,

• Real persons, legal entities and unincorporated organizations in whose name the goods subject to registration and licensing in the list numbered (II) annexed to the Special Consumption Tax Law are registered upon their first acquisition.

In this context, the electronic notification system continues to be a fundamental tax obligation for joint-stock companies, limited liability companies, self-employed individuals, and commercial enterprises taxed under the regular tax regime.

Another important point concerns the regulation regarding individuals acquiring vehicles. Individuals who do not own a commercial business or are self-employed may also be required to participate in the electronic notification system due to the initial acquisition of goods subject to registration and licensing under the relevant Special Consumption Tax (SCT). Therefore, it should not be assumed that the electronic notification obligation only concerns companies and active taxpayers.

What are the exceptions to the mandatory electronic notification requirement?

Article 6 of the new Circular lists the individuals and organizations that are not required to be included in the electronic notification system.

The main exceptions are:

• Individuals with a disability rate of 90% or more,

• In legal entities with a single legal representative or administrator, the relevant representative must have a disability rate of 90% or more; in entities with more than one representative or administrator, all of them must have a disability rate of 90% or more.

• Natural persons who have not reached the age of eighteen.

In addition, exceptions are provided for certain public administrations, local administrations, diplomatic missions, and international organizations specified in the Communiqué, regarding those who fall within the scope of electronic notification due to the initial acquisition of goods subject to registration and licensing. To benefit from the disability-based exemption, the relevant medical board report must be submitted to the tax office. It should be noted that the exemption provisions do not apply uniformly to all taxpayer groups, and the scope assessment should be made according to the relevant article of the Communiqué.

Application Deadlines for the Electronic Notification System

One of the important provisions of Circular No. 596 is the clear definition of the time periods for inclusion in the system.

Here, it is particularly important for individuals and corporations who are newly employed and subject to tax to pay attention to the 15-day application period.

For example, a limited company that establishes its tax liability on October 20, 2026, will need to complete its inclusion in the electronic notification system by November 4, 2026, according to general deadline calculation rules. However, taxpayers who joined the electronic notification system before July 1, 2026, are not required to reapply. These individuals can continue to use the system with their existing user codes and passwords.

When is an electronic notification considered served?

According to Article 107/A of the Tax Procedure Law, electronic notification is deemed to have been served five days after the date the electronic document reaches the recipient's electronic notification system. The practical significance of this provision is considerable. For example, a document sent to the electronic notification system by the tax administration on October 14, 2026, will be deemed served on October 19, 2026. The taxpayer reading the document after this date will not change the date of service.

The legally valid date of notification is used as the basis for calculating time limits for applications, payments, settlements, or lawsuits against tax or penalty notices. The specific time limits for each relevant action should be evaluated separately.

Therefore, regularly monitoring the electronic notification system is not merely an administrative follow-up process, but a necessity directly aimed at protecting the legal rights of the taxpayer.

If I don't receive an SMS or email notification, will the notification be considered invalid?

One of the most common problems in electronic notification systems is that taxpayers rely solely on SMS or email notifications. According to Article 10 of Circular No. 596, taxpayers can request notification to their registered phone numbers or email addresses when an electronic notification is sent. However, the failure to send these notifications for any reason does not affect the validity or delivery time of the electronic notification. In other words, a taxpayer who does not receive an SMS or email notification cannot claim that the notification is invalid simply because they did not receive it. Therefore, instead of relying on notifications, businesses should periodically check their electronic notifications through the Digital Tax Office and, if possible, establish a written workflow for this check.

Does the electronic notification system shut down when the obligation ends?

One of the provisions of the new regulation that requires careful consideration is the conditions for exiting the electronic notification system after the termination of tax liability. According to Article 11 of Circular No. 596, individuals who are compulsorily included in the electronic notification system may exit the system by submitting a request starting from the end of the fifth calendar year following the termination of their tax liability. This process does not occur automatically; it requires an application to the relevant tax office or through the Digital Tax Office. Furthermore, the individual must not have any other circumstances that necessitate their inclusion in the electronic notification system.

Example:

For a sole proprietor who ceases commercial activity on December 31, 2026, the end of the fifth calendar year following the year of termination of tax liability will be December 31, 2031. Therefore, if the taxpayer meets other conditions, they will be able to apply to opt out of the electronic notification system from this date onwards. This regulation demonstrates that the notion that the obligation to receive electronic notifications automatically ceases upon the termination of business activity is incorrect.

A different procedure applies to companies. Legal entities registered in the commercial registry are removed from the system as of the date their commercial registry records are deleted. Furthermore, it is stipulated that notifications will not be made to companies in liquidation or bankruptcy via the electronic notification system; provisions have been made regarding the optional application of the liquidator or bankruptcy administrator.

A New Right for Those Turning 65: Exiting the System

One of the prominent provisions of Circular No. 596 is the option for individuals who have reached the age of 65 to opt out of the electronic notification system. According to Article 11 of the Circular, individuals who are 65 years of age or older and included in the electronic notification system can opt out by applying to the relevant tax office or through the Digital Tax Office.

This regulation is particularly important for individuals who have been engaged in commercial or professional activities for many years and who have difficulty using digital applications. However, it is important to note that reaching the age of 65 does not automatically result in deregistration from the system. Deregistration requires a request from the taxpayer, and it takes effect from the date of the request. Therefore, reaching the age of 65 does not invalidate notifications previously sent electronically.

How to Apply to the E-Notification System?

With Circular No. 596, the Digital Tax Office has been highlighted in the application process. Individuals wishing to participate in the electronic notification system can carry out their transactions through the Digital Tax Office. Individuals who have not previously obtained a user code and password can create one by completing the appropriate identity verification and authorization processes. After logging into the system, electronic notification activation must be completed. Application procedures can also be carried out through the relevant tax office using the appropriate electronic notification request form. Applications to the tax office must be made in person by the taxpayer, their legal representative, or a person with a notarized power of attorney specifically authorizing them to handle electronic notification procedures.

How to Control Electronic Notifications for Businesses?

Since the electronic notification system has significant implications for tax processes, businesses should not view it as merely a platform accessed by the accounting department. Especially in companies with multiple managers or operational units, timely delivery of notifications to the relevant individuals is critically important.

For businesses, performing the following checks would be beneficial:

1. The registration and activation status of the electronic notification system should be checked.

2. The registered phone number and email address must be verified to be up-to-date.

3. It must be determined which authorized person will monitor the system.

4. The frequency and responsibility for checking notifications should be clearly defined.

5. A process should be established for forwarding incoming documents to the relevant financial advisor, legal counsel, or manager.

6. The deadlines for legal recourse regarding tax and penalty notices should be monitored separately.

Another important point to consider here is the protection of user codes and passwords used to access the electronic notification system.

Article 12 of the Circular stipulates that user codes and passwords should not be shared with third parties, and that if it is discovered that they have fallen into the hands of unauthorized persons, the situation must be reported immediately to the relevant tax office. Therefore, access rights should be managed in accordance with the legislation and the authorization options offered by the system, not through sharing personal passwords.

Consequences of Not Complying with the New Regulations

Article 13 of Circular No. 596 states that those who fail to comply with the imposed obligations will be subject to the relevant penalty provisions of the Tax Procedure Law. In this context, failure to join the electronic notification system on time or violation of the obligations specified in the Circular may result in tax penalties. However, the risk in the electronic notification system is not limited solely to administrative fines.

Taxpayers failing to monitor electronic notifications may be late in receiving notices or other documents sent by the tax administration, resulting in missed opportunities for applications, settlements, lawsuits, and payments. Therefore, proper system management is crucial not only for preventing penalties but also for protecting the legal rights of taxpayers.

Conclusion and Evaluation

General Communiqué No. 596 of the Tax Procedure Law is a significant legislative amendment that reorganizes the legal framework and implementation principles of the electronic notification system.

The application of a 15-day application period, especially for new tax obligations, the granting of exemptions to certain taxpayers, the ability for individuals aged 65 and over to opt out of the system upon request, and the regulation concerning the fifth calendar year following the termination of tax obligations should be carefully considered by taxpayers.

Furthermore, the fact that electronic notifications are deemed to have been delivered five days after their receipt by the system, and that the failure to deliver SMS or email notifications does not affect the validity of the notification, remains important in the current practice.

Our assessment at MindBack is that electronic notification should be considered not merely a technical notification system, but a vital part of companies' tax compliance processes and legal risk management.

Regular monitoring of electronic notifications, identification of authorized persons, and controlled management of deadlines will help reduce the tax and legal risks that businesses may face.

Legal Basis and Sources

• Tax Procedure Law No. 213, Article 107/A

• Law No. 7587, Article 9

• General Communiqué No. 596 of the Tax Procedure Law, published in the Official Gazette dated October 11, 2026, and numbered 33397.

• The repealed General Communiqué No. 456 of the Tax Procedure Law, published in the Official Gazette dated August 27, 2015, and numbered 29458.

• Turkish Revenue Administration – General Tax Procedure Law Circular No. 596