Deadline Looming for Turkey’s E-delivery Note Mandate – are you Ready?

Selin Adler Ring
May 13, 2020

Following the successful implementation of the e-invoicing mandate that has gradually expanded its scope, Turkey introduced a new mandate to track the movement of goods in a more technology-efficient way. Like many other countries, Turkey has already been able to retroactively track the movement of goods by obliging taxpayers to issue delivery notes. Having seen the benefits of the robust e-invoicing infrastructure, Turkey saw other opportunities to use its government platform. The e-delivery note mandate provides a prime opportunity to expand real-time data gathering beyond just invoice data.

Clarity from the TRA

The e-delivery note has the same legal status as the delivery note and will be mandatory for certain taxpayer groups. Even though the e-delivery note mandate is set to go live on 1 July 2020, full details have been outstanding. To provide clarity on the mandate, the Turkish Revenue Administration (TRA) recently published “Guidelines for the E-delivery note Application” (Guidelines),  which clarified many of the questions regarding the workflows of the application.

According to the Guidelines, taxpayers registered in the e-delivery note application must issue their delivery notes electronically even if the receiver isn’t registered in the application. However, if the receiver is also registered in the application, they can respond to the delivery note through the system.

E-delivery notes must be issued before the dispatch of goods occurs. However, how the issuance will be determined in the electronic system was a fair question asked by many taxpayers. According to the Guidelines, it’s now clear that the successful submission of the e-delivery note to the TRA portal must happen before dispatch of the goods begins. However, it’s not necessary to wait for the buyer’s response; after receiving a success message from the TRA, suppliers can go ahead and dispatch the goods.


Another important point is the barcode/QR code to be included in the e-delivery note. It is mandatory to include a QR code in the e-delivery note to enable its traceability, however the content of the QR code has yet to be determined by the TRA. Therefore, this requirement will only apply once the TRA publishes the necessary content information for the QR code.

The countdown is on

As the July deadline for the roll-out of the e-delivery note mandate is fast approaching, many companies are still struggling to catch up with the remaining open questions in order to prepare. Thankfully, the documentation provided by the TRA clarifies most of the questions raised by taxpayers so far. The biggest question that remains is one which has been asked many times before: will this mandate’s go-live date be delayed? For the time being, no delay has been communicated and businesses must continue to prepare to meet the July deadline.

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Selin Adler Ring

Selin is Regulatory Counsel at Sovos. Based in Stockholm and originally from Turkey, Selin’s background is in corporate and commercial law, and currently specializes in global e-invoicing compliance. Selin earned a Law degree in her home country and has a master’s degree in Law and Economics.
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