Among the four major secondary regulations related to crypto assets published in the Official Gazette on March 13, 2025, is the Communiqué Amending the Communiqué on Independent Audit of Information Systems (III-62.2) (“Communiqué”), issued by the Capital Markets Board and consisting of 5 articles. The Communiqué will enter into force on June 30, 2025.
The main amendments introduced by the Communiqué can be summarized as follows:
- Scope Changes: With the introduction of an obligation for crypto asset service providers (CASPs) to undergo an independent audit once a year, CASPs are now included within the scope of the Communiqué. Additionally, the exemption granted to companies subject to their own audit legislation is expanded to include savings financing companies, in addition to financing companies.
- Information Systems Independent Audit (ISIA) Report Deadlines: Previously, information systems audit reports received by the chairperson of the board of the relevant institution had to be submitted to the Capital Markets Board (“Board”) within five business days, and in any case, ISIA reports had to be submitted within 30 days following the end of the relevant audit period. Under the new regulation, the reporting obligation is simplified to a single deadline: ISIA reports received by the chairperson of the board must now be submitted to the Board by the end of the month following the end of the relevant audit period.
- Distinction for Portfolio Management Companies: Previously, the independent audit obligations for portfolio management companies were distinguished based on whether their minimum equity requirement was above or below TRY 5 million. Under the new regulation, this distinction is now made based on the equity thresholds introduced in 2023 under Article 28 of the Communiqué on Principles Regarding Portfolio Management Companies and Their Activities (III-55.1).
Full text of the Communiqué is available at: https://www.resmigazete.gov.tr/eskiler/2025/03/20250313-7.htm
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