Contents 10 sections
A company registered with a Turkish trade registry on or after 1 January 2026 must keep its share ledger and general assembly meeting and negotiation book in the Electronic Commercial Books System, known as ETDS. The books are created and activated automatically when the company is registered, but the founders still need to appoint a system user, confirm access and complete the first records.
The short answer for a newly registered company
ETDS setup should be treated as part of the incorporation closing checklist. Registration activates the relevant books, but it does not replace the company’s duty to identify a responsible user, verify imported shareholder information, add missing data and record later corporate decisions without delay.
What is ETDS in Turkey?
ETDS is the Ministry of Trade platform for electronic corporate books that are not accounting ledgers. Its Turkish name is Elektronik Ticari Defter Sistemi. The system opened on 1 July 2025 under the Communiqué on Keeping Non-Accounting Commercial Books Electronically.
For a foreign-owned Turkish company, ETDS sits within the corporate governance workflow. It records shareholders and corporate decisions; it is not the same as the Turkish Revenue Administration’s tax e-Ledger system.
| System | Main purpose | Responsible authority |
|---|---|---|
| ETDS | Shareholder and corporate-decision records | Ministry of Trade |
| Tax e-Ledger | Electronic journal and general ledger files based on accounting entries | Turkish Revenue Administration (GİB) |
Registration in one system does not by itself establish compliance with the other. A new company should therefore review ETDS separately from its invoicing, accounting and tax e-Ledger position. Our e-transformation and digital compliance service can be used to map these distinct obligations.
Which books must a company formed in 2026 keep in ETDS?
The Ministry of Trade’s 18 December 2025 announcement confirms the position for companies registered on or after 1 January 2026. The following practical matrix applies at formation:
| Corporate book | 2026 new company treatment | Formation-stage action |
|---|---|---|
| Share ledger (pay defteri) | Mandatory in ETDS | Check imported founders, holdings and missing shareholder fields. |
| General assembly meeting and negotiation book (genel kurul toplantı ve müzakere defteri) | Mandatory in ETDS | Establish the process for uploading meeting records and decisions. |
| Board resolution book (yönetim kurulu karar defteri) | Optional in ETDS | For a joint-stock company, document the chosen method and keep it consistent. |
Whether the entity is a limited liability company or a joint-stock company still matters for governance, management and decision-making. These questions should be settled during the company formation process in Turkey, rather than after the first corporate action is due.
ETDS checklist before the trade registry appointment
- Choose the system user. ETDS users must be natural persons. A manager, director, shareholder or properly authorised third party may be designated.
- Collect reliable identity data. Confirm the user’s Turkish ID number, foreigner ID, Blue Card details, tax identification number or passport information, as applicable.
- Agree the authority model. Decide who may create, view, update or delete records. These permissions can be defined separately.
- Align the MERSIS file. Names, capital, shareholding and management data in the incorporation application should be consistent with the supporting documents.
- Record the designation. The first user is determined through MERSIS and the trade registry process. Do not leave this choice until after registration.
- Assign an owner for the post-registration check. Someone should log in promptly, review the created books and report any access or data gap.
Can a foreign director or shareholder use ETDS?
Yes. The Ministry’s official ETDS guidance states that a system user may be a foreign national and does not need to reside in Turkey. A foreign user who does not have a Turkish foreigner identification number or Blue Card can use the platform’s separate login route if the required tax identification number or passport number, email address and nationality information have been registered through the notary or trade registry.
This makes identity preparation important for remote formations. An overseas director should not assume that a power of attorney used for incorporation automatically completes every digital-access step. The registry file, user designation and contact details should be checked together.
Access-control warning
ETDS allows more than one user for a book and different users for different books. Convenience should not replace control: give each person only the permissions needed for their role, keep an internal approval trail and review access when a manager or adviser changes.
What happens immediately after registration?
For a newly registered company within the mandatory scope, the relevant books are created and activated automatically when trade registry registration is completed. No separate book-opening application is required. That automation is only the beginning of the compliance process.
1. Verify the initial share ledger
Founders and initial share information in the articles of association are transferred from MERSIS. The designated user must enter any remaining required fields and check the complete record against the registered articles and supporting documents. Foreign shareholders follow the same ETDS share-ledger process; their nationality does not create a separate electronic book.
2. Prepare the general assembly workflow
When a general assembly is held physically, the signed meeting record is scanned and uploaded as a PDF. Corporate decisions and related entries must be added without delay. Build the workflow before the first meeting: finalise the signed original, scan it clearly, name the file consistently, upload it and perform a second-person check.
3. Reconcile the corporate record
Compare ETDS with the articles of association, MERSIS record and Turkish Trade Registry Gazette announcement. The Gazette is an important evidence source, but later changes can supersede the formation announcement. See our guide to verifying Turkish company records through the Trade Registry Gazette.
Who remains responsible for the electronic books?
The Ministry operates the platform, but this does not transfer the directors’ or managers’ legal responsibility for the company’s books. Management should be able to show who prepared each entry, which underlying document supports it, who reviewed it and when the record was completed.
Corrections should also be handled carefully. The system retains an audit trail, so an inaccurate entry should not be treated as if it can simply disappear. Preserve the supporting explanation and approval for any amendment.
A practical ETDS control file for foreign-owned companies
- Trade registry registration certificate and formation Gazette announcement
- Final articles of association and current MERSIS information
- List of ETDS books created for the company
- System-user designation and identity details
- Permission matrix showing create, view, update and delete rights
- Screenshot or internal confirmation of successful first access
- Reconciled opening shareholder schedule
- Procedure for uploading meetings and decisions without delay
- Quarterly access review and event-based reconciliation after share or management changes
Add ETDS to your incorporation closing checklist
We can review the user designation, initial shareholder record and post-registration corporate-book workflow alongside your company formation and digital compliance setup.
Official sources
Share this guide with your network
Choose a platform and share the article with its title, link and preview image ready.
Need advisory on this topic?
Contact us by WhatsApp or phone, or submit your request using the short form below.
