Yes. Article 28 of the Regulation on Official Announcements and Advertisements is a single sentence and leaves no room for doubt: newspapers and online news sites must arrange their accounts on the balance sheet basis.
The provision covers both types of publication
The striking feature of the article is that it covers not only newspapers but online news sites. Because it sits in the general provisions of the Regulation, it applies to both types of publication concerned with the publication of official announcements.
Saying “we are only an online news site, we have no printed newspaper” does not remove that obligation.
The difference between the balance sheet basis and the operating account basis
Commercial income may be determined by two methods under Turkish tax legislation. The difference lies in the scope of the records kept:
| Subject | Operating account basis | Balance sheet basis |
|---|---|---|
| Records kept | Income and expense records | Journal, general ledger and inventory ledger |
| Financial statement | Operating account summary | Balance sheet and income statement |
| Tracking of assets and liabilities | Limited | Detailed |
| Compliance burden | Lighter | Heavier |
The Regulation makes the second method compulsory for publications carrying official announcements. The reason is plain: the official announcement right is a distribution of publicly sourced revenue, and the financial structure of the right-holder is required to be traceable.
Do not confuse this with the sectoral ledgers
Balance-sheet accounting does not replace the sectoral ledgers the Regulation separately requires. Article 37 provides for four separate ledgers for newspapers: the paper, print, subscription and sales ledgers. They are kept on İLANBİS and contain the information relating to every printed issue forming the basis of the official announcement right.
| Arrangement | Basis | Purpose |
|---|---|---|
| Balance-sheet accounting | Reg. Art. 28 | Traceability of the financial structure |
| Sectoral ledgers | Reg. Art. 37 | Documentation of the printing, distribution and sales chain |
The two run together and feed one another: the figures in the sales ledger and the revenue in the accounting records must be consistent. What the sectoral ledgers contain is covered in the sectoral ledger guide.
The relationship with invoicing
The direct consequence of the accounting arrangement shows on the invoice. Under Article 27 newspapers and online news sites must issue invoices for the official announcements they publish over the amount remaining after deducting the Agency commission from the fee calculated according to the tariff. The commission rate is 15% under Article 116.
The second paragraph of the same article states that where an invoice is issued contrary to the tariffs or to the principles in the Regulation, or is not issued at all, the application of sanctions under the relevant laws does not prevent proceedings under Article 49 of Law No. 195. See the commission guide.
What is asked on inspection?
Inspection boards look at the consistency between the financial records and the sectoral ledgers. Commonly encountered inconsistencies:
- The newsagent figures in the sales ledger not matching the revenue records
- The number of subscribers shown in the subscription ledger not matching the subscription invoices issued
- The print run in the print ledger being out of proportion to paper consumption
- Official announcement invoices having been issued over the gross fee
Conclusion
Newspapers and online news sites publishing official announcements must arrange their accounts on the balance sheet basis (Art. 28). That obligation is separate from the sectoral ledgers kept on İLANBİS and does not replace them; the two run together and their consistency is examined on inspection.
The premises requirement is covered in the premises guide and the ledgers in the sectoral ledger guide.