Türkiye CPD: Two Regimes, Both 120 Credits

A Turkish accountant can be subject to two separate continuing education regimes at the same time. Both total 120 credits over three years. They are not the same 120 credits, they are not interchangeable, and a statutory auditor who is also a practising fiscal adviser has to satisfy both.

Of every jurisdiction we have examined at primary source, Türkiye has the clearest and best-documented licensed-versus-member split.

Regime one: the audit regulator

Statutory auditors answer to KGK — in full, the T.C. Kamu Gözetimi, Muhasebe ve Denetim Standartları Kurumu, the Public Oversight, Accounting and Auditing Standards Authority. Its instrument is the Continuing Education Communiqué for Independent Auditors, published in the Official Gazette No. 30230 of 4 November 2017 and in force on publication.

It has been amended twice: once in May 2019, and once on 31 December 2023, with the substantive changes taking effect from 1 January 2024.

The requirement:

• 120 credits over a three-year cycle
• At least 60 of the 120 from core professional subjects
• At least 20 core credits every year, so the cycle cannot be back-loaded
• At most 60 from supporting subjects
• At least 5 credits on ethics across the three years

One credit is a 50-minute lesson, in person or remote. The obligation starts from the beginning of the second calendar year after registration.

The sector add-ons, assessed separately

This is a feature we have not found elsewhere. Auditors of banking-regulated companies must obtain at least 7 banking credits, and auditors of insurance, reinsurance or pension companies at least 7 insurance and private pension credits, by the end of the year in which the audit contract is signed.

Crucially, these are assessed separately from the 120. They are not a subset of the general requirement; they are an additional obligation triggered by the client base. An auditor picking up a first bank audit acquires a training obligation in the same year.

Quarterly filing, and a hard penalty for lateness

Where most regimes ask for an annual declaration, KGK asks every three months: credits must be reported electronically by the 15th of the month following each three-month period.

And the sanction for missing that window is unusually direct. Late filing earns no credit. Not a fine, not a warning — the training simply does not count. You can attend a qualifying course, pay for it, learn from it, and have it score zero because the declaration was late.

That is a materially different enforcement design from the penalty structures we survey elsewhere, most of which treat reporting failure and training failure as separate problems. Türkiye collapses them.

What the 2024 amendment changed

The December 2023 amendment is the live change in Turkish CPD, and it did five things worth knowing:

• Added Turkish Sustainability Reporting Standards (TSRS) and information systems auditing to the core subject list — the most consequential substantive change
• Introduced the concept of an eğitim açığı, a formally defined training deficit, with an extension of up to three months available on documented good cause
• Added the 7-credit banking and insurance add-ons described above
• Capped remote learning in core subjects at 7 credits a year, with excess reclassified as supporting; the regulator may raise that cap to no more than 20
• Required at least 15 days' advance notice for congresses and seminars, with electronic participant reporting — and removed credit for in-house or closed-group training entirely

That last point reshapes the Turkish market. A firm can no longer satisfy its auditors' core CPD with internal training, which pushes demand toward recognised external providers. Teaching, by contrast, is generously treated: up to 40 credits a year for instruction in core subjects, and 20 credits for passing a KGK auditing exam subject, once per cycle.

The total remained 120 and the five-credit ethics minimum was untouched.

Regime two: the professional body

TÜRMOB — the union of chambers of certified public accountants and sworn-in certified public accountants — sets its own requirement for its SMMM and YMM members, deriving its scope from the 1989 professions law. Its figures:

• At least 30 credits a year, and at least 120 per three-year cycle
• Of which at least 15 a year and 60 per cycle must be verifiable
• "Other activities" capped at 60 credits per cycle
• At least 3 credits per cycle on professional standards and ethics
• At least 2 credits per cycle on audit and assurance standards
• One credit is a 50-minute lesson, with a maximum of 7 credits a day

Compliance is assessed every year, looking back across the two preceding years. Verifiable credits above 60 in a cycle do not carry forward.

Scope is worth noting: the requirement applies to members on the practising list, runs from the year after the licence is obtained, and continues during a temporary suspension of practice — a point relevant to anyone reading our post on CPD for non-practising and retired accountants, since Türkiye answers that question differently from most.

Someone newly entering scope has no 30-credit requirement in their first year, but must complete that year's obligation by the end of the second calendar year.

The interlock between the two — the practical point

Here is where the two regimes meet, and it is the single most useful fact in this article for anyone planning Turkish CPD.

For TÜRMOB purposes, KGK training in core topics counts as verifiable, while KGK training in supporting topics counts only toward the capped "other activities" bucket.

So a KGK-registered course in a core subject does double duty: it satisfies KGK's core requirement and TÜRMOB's verifiable requirement simultaneously. A KGK supporting-subject course satisfies KGK's supporting allowance but only feeds TÜRMOB's capped bucket — and that bucket fills.

Anyone holding both statuses should therefore weight their training heavily toward core subjects. It is the clearest case we have found of overlapping CPD obligations where the overlap is explicitly defined rather than left to the practitioner to argue.

Recording and what is not specified

TÜRMOB maintains a central training register. In-person attendance is recorded by the chambers via a membership card and QR code with no member declaration needed; synchronous online training requires at least 80% attendance; asynchronous requires course completion plus an evaluation survey. Only "other activities" are self-declared.

Central record-keeping is a genuine structural difference from Indonesia, where the individual files an electronic return each January and carries the evidential burden personally.

Neither regime specifies a record-retention period. KGK requires supporting documents to be filed within the deadline and produced on request; TÜRMOB holds the register centrally. The absence appears deliberate rather than accidental, but we are stating it as an absence rather than inferring a period.

We are also not citing a gazette date for the TÜRMOB regulation. A date is indicated by a search result, but the Official Gazette and the consolidated legislation database both refuse automated access, so we could not confirm it and have left it out.

KGK publishes the communiqué and its amendments on its own site at kgk.gov.tr.

In summary

Two regimes, both 120 credits per three years, differing in annual floor (20 core versus 30 total), ethics minimum (5 versus 3), filing rhythm (quarterly versus continuous) and sector add-ons (7 credits versus none). They are cumulative, not alternative.

Türkiye is the strongest available answer to anyone who assumes that two regimes landing on the same total must be asking for the same thing — the argument we make at length in why CPD hours do not convert between countries.