The Regulation on Official Announcements and Advertisements imposes document obligations in two separate articles: Article 99 governs the documents that must be kept, Article 100 the archive that must be produced. They are different things and both are sought on inspection.
Documents that must be kept (Art. 99)
Article 99(1) lists four sources for newspapers and requires every kind of document relating to each — waybills, invoices, contracts and the like — to be kept:
| Source | Example document |
|---|---|
| The printing house where they are printed | Printing contract, print docket, invoice |
| The vendors from whom paper is bought | Waybill, invoice |
| The newsagents carrying out distribution | Distribution contract, dispatch waybill, return documents |
| Persons relating to subscription sales | Subscription invoices and records |
The article requires not only keeping those documents but also taking the measures that will ensure the documents and the information relating to them can be obtained. Having access to a document held by a third party is therefore also your responsibility.
The second paragraph is for online news sites: in addition to keeping every kind of document relating to the hosting provider, such as the contract and invoices, the measures ensuring those documents can be obtained must be taken.
The archive to be produced (Art. 100)
Article 100 determines what must be kept ready to allow examination at the request of inspection boards:
| Type of publication | Obligation to produce |
|---|---|
| Newspapers | Keeping ready collections for at least the last 2 years and producing the printing plates for every page of the last 3 issues published |
| Online news sites | Producing at least 2 years of content |
The two-year content production requirement for online news sites overlaps with the two-year retention obligation in Article 10 of Law No. 5187. The same archive serves two separate sets of legislation.
Sectoral ledgers
The third leg of the document obligation is the ledgers. Under Article 37 newspapers record the information relating to every printed issue forming the basis of the official announcement right in the ledgers on İLANBİS: the paper ledger, the print ledger, the subscription ledger and the sales ledger.
All information other than return quantities is entered daily, and return quantities within 10 days at the latest. What the ledgers contain is covered in the sectoral ledger guide.
What inspection looks for is consistency between those three layers: the figure in the ledger, the invoice in your hands and the record coming from the printing house must all say the same thing.
Accounting records
Under Article 28 newspapers and online news sites must keep their accounts on the balance sheet basis. Consistency between the financial records and the sectoral ledgers is also assessed on inspection; see the bookkeeping guide.
Roster documents
Article 18 ties the quality of the roster to documents. The items cross-checked on inspection:
- Written, full-time employment contracts complying with Law No. 5953
- Records showing the wage was paid in advance over a full day and a full month
- Social security notifications and premiums and the tax accruals on wages
- Diplomas, press cards or service documents showing the qualification condition in Article 19
- National population register records for establishing residence (the primary address is the basis)
That roster changes were notified to İLANBİS within three working days is also separately checked (Art. 22).
Conclusion
Three layers are sought on inspection: the documents to be kept (printing house, paper, newsagent, subscription; for sites, the hosting contract and invoices), the archive to be produced (for newspapers a two-year collection and the printing plates of the last three issues; for sites two years of content) and the ledgers (paper, print, subscription, sales). Roster and accounting records are added to those.
What inspection boards check is covered in the inspection scope guide and the consequence of obstruction in the obstruction guide.