Turkey FX Conversion Support 2026: New 10% FX Position Test, Certification Requirements and Value-Added Limits
From 1 October 2026, Türkiye’s foreign exchange conversion support scheme operates under a materially different framework. The previous one-month commitment not to purchase foreign currency has been removed and replaced by a balance-sheet-based FX position test, while firm-level support limits are now linked to domestic value added.
Executive Summary
- Effective 1 October 2026, companies no longer need to undertake not to purchase foreign currency for one month after benefiting from the FX conversion support scheme.
- Instead, an eligible company’s FX position ratio must not exceed 10%.
- The ratio compares specified liquid FX assets with the higher of the company’s net sales revenue or total assets.
- The annual amount of export proceeds eligible for the scheme is now linked to the company’s value added, calculated principally by reference to operating profit and labour costs.
- The overall FX conversion support available to a company is subject to an annual cap of TRY 100 million.
- In banking practice, companies may also need an FX Position Notification Form prepared and certified by a Turkish Certified Public Accountant (SMMM) or Sworn-in Certified Public Accountant (YMM), together with supporting professional documentation.
What Changed in Turkey’s FX Conversion Support Scheme?
Türkiye’s foreign exchange conversion support mechanism was introduced to encourage companies to convert qualifying foreign-source FX revenues into Turkish lira.
The framework has become increasingly relevant to exporters, service exporters and companies generating foreign-currency revenues. According to the Central Bank of the Republic of Türkiye (CBRT), approximately 44,000 firms have benefited from the scheme since its introduction in 2023, while the share of beneficiary firms among exporters reached approximately 34% in 2026.
The rules applicable from 1 October 2026 represent a structural change. Eligibility is no longer primarily based on a post-conversion restriction on purchasing foreign currency. Instead, the CBRT is placing greater emphasis on the company’s actual balance-sheet FX position and the economic value created through domestic operations.
1. The New 10% FX Position Ratio Test
To benefit from the scheme under the new framework, the company’s FX position ratio must not exceed 10%.
The CBRT describes liquid FX assets as including specified foreign currency-denominated balances such as cash, bank deposits, securities, certain checks and payment instruments, and receivables from shareholders, affiliates and subsidiaries.
Example
Net sales revenue: TRY 60 million
Total assets: TRY 80 million
Relevant liquid FX assets: TRY 6 million equivalent
The denominator is TRY 80 million because total assets exceed net sales revenue.
FX position ratio = TRY 6m ÷ TRY 80m = 7.5%
Subject to the remaining conditions and applicable limits, the company would satisfy the 10% FX position ratio test.
If the same company held TRY 10 million equivalent of relevant liquid FX assets, the ratio would increase to 12.5%. It would therefore fail the 10% test for the relevant assessment.
2. One-Month FX Purchase Restriction Removed
Under the previous mechanism, a company receiving FX conversion support generally committed not to purchase foreign currency for one month.
For new transactions from 1 October 2026, this commitment has been removed. The FX position ratio test now performs the principal balance-sheet control function.
| Area | Previous Framework | From 1 October 2026 |
|---|---|---|
| FX purchase restriction | One-month commitment generally applied | Removed for new transactions |
| FX balance-sheet test | Not the central eligibility mechanism | FX position ratio must generally be ≤10% |
| Firm-level limit | Different framework | Linked to value added |
| Supplier access | More limited in practical use | Framework facilitates direct benefit for eligible suppliers |
3. Support Limits Are Now Linked to Value Added
One of the most significant changes for larger exporters is the introduction of a firm-level value-added limitation.
Under the new framework, the amount of export proceeds that a company can sell under the FX conversion support mechanism within a year is linked to the value added generated by the company.
For companies reporting a negative operating profit, the CBRT framework treats the operating profit component as zero for this calculation.
Accordingly, the new rules make the interaction between statutory accounting, corporate tax reporting, payroll data and treasury operations significantly more important.
4. TRY 100 Million Annual Support Cap
The total FX conversion support available to a company is capped at TRY 100 million per year.
The final quarter of 2026 is treated as the first limit-utilisation period. For this period, one quarter of the calculated annual value added and one quarter of the annual support cap apply.
5. What Is the FX Conversion Support Rate?
The support rate was originally 2% of the Turkish lira equivalent of qualifying FX converted under the scheme.
The rate was temporarily increased to 3%, and according to the CBRT’s September 2026 explanation, the temporary 3% rate remains applicable until 31 January 2027.
Companies should nevertheless verify the rate, transaction eligibility and available limits applicable on the actual conversion date.
6. FX Position Notification Form and SMMM/YMM Certification
The new balance-sheet test also creates an additional documentation requirement in banking practice.
Companies seeking to execute qualifying transactions may be requested to provide an FX Position Notification Form prepared and certified by their Turkish Certified Public Accountant (SMMM) or Sworn-in Certified Public Accountant (YMM).
The documentation package may include:
- the completed FX Position Notification Form;
- company approval/signature;
- SMMM or YMM certification;
- a valid professional activity certificate demonstrating the accountant’s registration with the relevant professional chamber; and
- underlying accounting and financial records supporting the calculation.
Banks may independently verify the validity of the professional activity certificate.
7. The Form Is Generally Valid for 15 Days
Based on current banking implementation, the FX Position Notification Form is valid for 15 days from its date of preparation.
Multiple qualifying FX conversion transactions may generally be completed using the same form during its validity period, subject to continuing compliance with the applicable rules and available limits.
For businesses with frequent export receipts, this makes timing important. Treasury teams should coordinate the certification date, expected FX collections and planned conversion transactions.
8. The New Framework Is More Relevant to Export Suppliers
The October 2026 framework is designed not only for direct exporters. It also seeks to improve access for Turkish companies that produce goods for export through intermediary exporters.
Under the new structure, after an intermediary exporter reaches its own firm-level value-added limit, it may convert qualifying FX proceeds on behalf of an eligible supplier, with the support transferred directly to the supplier.
A similar mechanism may also apply to intermediaries in foreign currency-earning service activities and the underlying service providers.
This can be particularly relevant for manufacturing suppliers, tourism businesses, agencies and other companies participating indirectly in export or service-export chains.
What Does This Mean for Foreign-Owned Companies in Türkiye?
For Turkish subsidiaries of multinational groups, the new framework should be considered not merely as a bank transaction issue but as part of the company’s broader statutory accounting and treasury controls.
Areas finance teams should review
- reconciliation of local statutory ledgers with group reporting;
- classification of FX cash and bank balances;
- foreign-currency securities and financial investments;
- intercompany and shareholder receivables;
- year-to-date sales and total asset balances;
- operating profit used in the value-added calculation;
- Turkish payroll and employer social security costs;
- remaining CBRT conversion limits; and
- timing of treasury conversions and expected FX requirements.
A company may appear operationally eligible but fail the 10% test because of excess FX cash, an intercompany balance or another liquid FX asset recorded in its Turkish statutory accounts.
Conversely, companies that were previously unable to use the programme because they needed to continue purchasing FX for imports or operating expenses may find the new framework more workable, provided that they satisfy the FX position ratio and other requirements.
Recommended Process Before an FX Conversion
Prepare an up-to-date trial balance
Use accounting records that are sufficiently current to support the transaction-date assessment.
Identify relevant liquid FX assets
Review bank balances, cash, securities, payment instruments and relevant shareholder or group-company receivables.
Determine net sales and total assets
Establish the appropriate denominator for the 10% FX position test.
Calculate the FX position ratio
Confirm that the ratio does not exceed the applicable 10% threshold.
Review the company’s value-added limit
Check operating profit, payroll data and the firm’s available annual or Q4 2026 limit.
Prepare and certify the notification package
Complete the required SMMM/YMM certification and supporting documentation requested by the bank.
Confirm bank and CBRT eligibility before execution
The conversion should be coordinated only after confirming that the transaction remains within the relevant programme limits.
What Happens if the Information Is Incorrect?
The information included in the FX position documentation should be complete, accurate and reconcilable to the company’s books and supporting records.
Where support has been obtained on the basis of incorrect or misleading information or documentation, recovery of the support together with applicable interest, taxes or other financial consequences may arise under the relevant rules. Further restrictions on access to support or financing programmes may also become relevant depending on the circumstances.
For material transactions, companies should therefore perform a pre-conversion reconciliation rather than preparing the calculation solely from headline balance-sheet figures.
Frequently Asked Questions
What is the FX position limit from 1 October 2026?
The FX position ratio should not exceed 10%. Broadly, the ratio compares relevant liquid FX assets with the higher of net sales revenue or total assets.
Does the one-month restriction on buying foreign currency still apply?
For new transactions under the framework effective from 1 October 2026, the previous one-month commitment not to purchase FX has been removed and replaced by the FX position ratio condition. Earlier outstanding commitments should be reviewed separately.
What is the FX conversion support rate in late 2026?
The temporary support rate is 3%, with the current temporary rate scheduled to remain in effect through 31 January 2027, subject to the applicable programme rules.
Is there an annual support cap?
Yes. The CBRT framework provides for a TRY 100 million annual firm-level cap on FX conversion support. Separate value-added limits also apply.
How is value added calculated?
The framework generally uses annual operating profit plus 12-month labour costs. Where operating profit is negative, the operating profit component is treated as zero.
Does the FX Position Notification Form require accountant certification?
Under current banking implementation, companies may be required to submit a form prepared and certified by an SMMM or YMM together with supporting professional documentation. The precise document package should be confirmed with the relevant bank before execution.
Can suppliers that are not direct exporters benefit?
The new framework is intended to improve access for suppliers producing goods for export. In qualifying structures, an intermediary exporter may perform the conversion on behalf of the supplier, with support paid directly to the supplier.
Can service exporters use the framework?
Qualifying foreign-currency-earning service transactions may also fall within the mechanism, subject to the specific documentation, eligibility and implementation rules applicable to the service activity.
Need to Confirm Your Company’s Eligibility Before Converting FX?
SystemsCPA supports Turkish subsidiaries, exporters and multinational finance teams with the accounting and certification work required before an FX conversion support transaction.
- FX position ratio calculation
- Trial balance and account reconciliation
- SMMM certification support
- FX Position Notification Form preparation
- Value-added limit review
- Export and service-export documentation review
- Bank documentation coordination
- Turkish statutory accounting review
Turn Turkey compliance into certainty
SYSTEMS CPA supports foreign-owned companies with company formation, accounting, tax compliance and payroll in Turkey — one accountable local partner. Reviewed by Evren Özmen, SMMM (Certified Public Accountant), TÜRMOB Reg. No. 35675.
