In January 2018, Turkey’s Capital Markets Board (“Board”) introduced new rules requiring capital markets institutions and publicly held companies to locate their primary and secondary information systems within Turkey (more). However, the Board has now announced an exemption for publicly held companies.

Therefore, publicly held companies which are not subject to periodic information systems auditing are exempt from being required to locate their primary information systems within Turkey.

However, the Board also noted that information systems audit obligations will gradually expand over time, with publicly held companies facing audits at a later date. Therefore, publicly held companies will be required to have their primary information system located within Turkey at some point, so these companies should plan accordingly.

Please see this link for the full text of the Board’s decision number i-SPK.62.1 (only available in Turkish).

Information first published in the MA | Gazette, a fortnightly legal update newsletter produced by Moroğlu Arseven.