Hybrid Working in Turkey: New Employment Contract Requirements from 25 September 2026

What changed?

The Regulation Amending the Remote Working Regulation was published in the Official Gazette dated 25 September 2026, No. 33381 and entered into force on the same date.

A new paragraph was added to Article 9 of the Remote Working Regulation. Under the amended rule, an employee may perform part of the work at the workplace and part remotely.

Where this hybrid model is used, the employment contract should specify:

• the days on which the employee will work at the workplace;
• the days on which the employee will work remotely; and
• the applicable working hours.

The amendment therefore makes the contractual documentation of hybrid working arrangements more explicit.

Was hybrid working previously prohibited?

No. The original Remote Working Regulation published in 2021 already defined a remote employee as an employee who performs all or part of the work remotely.

The September 2026 amendment is therefore better understood as a clarification and formalisation of hybrid-working arrangements rather than the creation of an entirely new employment model.

The practical difference is that the allocation of workplace days, remote-working days and working hours is now expressly addressed in the Regulation.

What should employers do now?

Employers currently using hybrid-working arrangements should review whether actual working practices are properly reflected in their employment documentation.

Arrangements of this kind should not remain solely as an informal practice, manager approval or internal email where the employment contract does not reflect the hybrid structure.

1. Employment contracts

Contracts should clearly reflect the employee’s workplace and remote-working days together with the applicable working hours.

For existing employees, this may be dealt with through an additional protocol or contractual amendment rather than replacing the entire employment agreement.

2. Remote-working policies

Employers should verify that internal remote-working policies are consistent with individual employment contracts and actual working practices.

3. Working-time records

Hybrid working does not remove the employer’s existing obligations relating to working hours, overtime and working-time records.

4. Remote-working expenses

Employers should also consider whether the employment documentation appropriately addresses mandatory expenses directly connected with remote work.

• internet and communication costs;
• computer and other equipment;
• home-working related expenses; and
• employer-provided devices and materials.

5. Data protection and information security

Hybrid-working arrangements should also remain aligned with company policies on confidentiality, cybersecurity, personal data protection and use of company equipment.

Does the amendment change payroll or tax rules?

Not directly.

The amendment is principally an employment-law and documentation change. It does not itself create a new income-tax exemption, payroll incentive or social-security exemption.

However, the contractual identification of where an employee performs their duties may become relevant in tax, payroll and social-security analysis, particularly in cross-border cases.

Foreign employers with employees working from Turkey

The amendment is particularly relevant for international companies allowing personnel to work from Turkey.

A common scenario involves an employee who remains employed by a foreign company while performing some or all of their duties physically from Turkey.

In these cases, employers should distinguish between three separate areas:

The revised Remote Working Regulation does not itself answer these tax questions. However, clearer contractual documentation of where employees perform their duties may become an important factual element in analysing them.

Practical example

Consider a multinational company with an employee based in Istanbul.

The employee works:

• three days per week from an office in Istanbul; and
• two days per week from home.

Following the 25 September 2026 amendment, the employment documentation should identify the relevant workplace days, remote-working days and applicable working hours.

If the employer is a Turkish company, the main considerations will generally concern employment and payroll compliance.

If the employer is a foreign company without an established Turkish entity, the analysis may also include Turkish payroll, social-security and corporate-tax considerations.

Does every hybrid employee need a new contract?

Not necessarily.

The appropriate implementation method depends on the wording of the existing employment contract and the company’s current remote-working documentation.

In many cases, an additional protocol or amendment to the existing employment agreement may be sufficient.

Employer checklist

Effective date

The amendment was published in the Official Gazette dated 25 September 2026 and numbered 33381, and entered into force on the date of publication.

Employers currently operating hybrid-working arrangements should therefore review their employment documentation rather than waiting until the next employment-contract renewal cycle.