"My buyer is not an e-Fatura (Türkiye's e-Invoice system) user; must I still issue an e-Arşiv Fatura (e-Archive Invoice)?" The rule change at the start of 2026 put this question back on many businesses' agenda. The answer turns on two questions: whether the business is included in the e-Arşiv application, and to whom the invoice is issued.
This article summarizes the current text of VUK (Tax Procedure Law) General Communiqué Serial No. 509, published by the Turkish Revenue Administration (GİB), then looks at how the e-Arşiv process can be automated. e-Fatura transition thresholds are covered in the e-Fatura article, the dispatch note in the e-İrsaliye article and the statutory ledgers in the e-Defter article; this article covers e-Arşiv Fatura only.
What is an e-Archive invoice (e-Arşiv Fatura)?
Per the communiqué's definitions section, an e-Arşiv Fatura is an electronic invoice, created in line with the communiqué's conditions, that falls outside e-Fatura. In other words, while an e-Fatura travels between two registered users through GİB, an e-Arşiv Fatura is the electronic invoice issued to buyers not registered in the e-Fatura system.
Section IV.2.1 clarifies the document's nature: an e-Arşiv Fatura is not a new document type but has the same legal characteristics as a paper invoice. The version sent to the buyer on paper or electronically is the invoice's original, while the issuer's electronically stored copy has the status of a second copy. Under Section V.5.2, electronic transmission needs no separate paper printout.
Is an e-Archive invoice mandatory, and for whom?
Section IV.2.2 states that e-Arşiv is not mandatory for anyone outside the groups listed in Section IV.2.4 of the communiqué, and that others who wish to may join provided they are included in e-Fatura and apply. The requirement falls into four groups:
- e-Fatura users (IV.2.4.1). Taxpayers included in the e-Fatura application, whether mandatorily or voluntarily, must also move to the e-Arşiv Fatura application. Those who, by the nature of their activity, issue other documents that take the place of an invoice are excluded from this rule.
- Internet sellers and intermediaries (IV.2.4.2). Intermediary service providers, websites that publish real estate and motor vehicle listings, and internet advertising intermediaries are covered. Those who sell goods or services on their own websites or on intermediary platforms must move to e-Arşiv by the start of the seventh month after the accounting period in which they meet the communiqué's revenue condition. That condition is tied to the e-Fatura threshold; the details are in the e-Fatura article.
- Invoices of taxpayers not included in e-Arşiv (IV.2.4.3). This section is covered separately below.
- Taxpayers designated by GİB (IV.2.4.4). GİB can bring taxpayers it considers risky or low in tax compliance into scope, regardless of activity, sector and turnover, by giving written notice and at least three months to prepare.
The 2026 rule: "regardless of the amount"
Section IV.2.4.3 was amended by Communiqué Serial No. 589, published in the Resmî Gazete (Türkiye's Official Gazette) of December 31, 2025. According to the current text, invoices issued by taxpayers that are not included in the e-Arşiv application,
- between January 1, 2025 and December 31, 2025, if the total amount including taxes exceeds 3,000 Turkish lira,
- from January 1, 2026, regardless of the amount
must be issued as an e-Arşiv Fatura. For taxpayers whose commercial income is determined under the simplified procedure (basit usul) and for those who keep books on a business-account basis (işletme hesabı esası), the first period was extended to December 31, 2026; for these groups, the obligation regardless of the amount begins on January 1, 2027.
These invoices are issued through GİB's e-Belge (e-Document) issuance portal or through the systems of private integrators authorized by GİB. The same section adds one more reminder: if both the seller and the buyer are e-Fatura users, all invoices between them must be e-Fatura.
When is an e-Archive invoice issued?
The buyer determines the document type. Under Section IV.2.1, a taxpayer registered in e-Arşiv issues an e-Fatura to an e-Fatura user, and an e-Arşiv Fatura to a taxpayer not registered in e-Fatura or to a non-taxpayer. The situations that stand out in practice are these:
- Sales to the end consumer. An invoice issued to an individual customer is an e-Arşiv Fatura.
- Sales to a business that is not an e-Fatura user. Even if the buyer is a taxpayer, an invoice to a buyer not registered in e-Fatura is issued as an e-Arşiv.
- Internet sales. Under Section IV.2.4.5, these invoices must be transmitted electronically. They must show the web address where the sale was made, the payment method and date, the carrier information and the dispatch date, and must also carry the statement "Bu satış internet üzerinden yapılmıştır." ("This sale was made over the internet").
- An invoice handed over with the goods. Under Section V.5.2, an e-Arşiv Fatura handed over on paper with the goods can replace an invoice with a dispatch note (irsaliyeli fatura). This requires the hour and minute of issue to be shown, the invoice to be issued at the moment of delivery, the statement "İrsaliye yerine geçer." ("Takes the place of a dispatch note") and a signature.
Reverting to paper is possible only in limited cases. Section V.7 provides that no special irregularity penalty (özel usulsüzlük cezası) is imposed for issuing on paper when there is a malfunction, interruption or planned maintenance in GİB's or the taxpayer's systems, or the malfunction or theft of the financial seal (mali mühür) or electronic signature device, provided the statutory issuance period is not exceeded. Other reasons attributable to the taxpayer are not covered. Sections IV.2.5 and V.6 refer to the VUK's penalty provisions for those who do not move to e-Arşiv although required, or who issue invoices on paper. We recommend confirming your own situation with your certified public accountant (mali müşavir).
Automating the e-Archive invoice process
In e-Arşiv, every invoice also carries a reporting obligation: under Section V.8, authorized taxpayers and private integrators must transfer the report on the e-Arşiv invoices they issue to the GİB system with a time-stamped signature. As invoice volume grows, doing these steps by hand raises the risk of error. The main recommendations:
- Let the system choose the document type. Whether the buyer is an e-Fatura user can be queried at the moment of invoicing, and the document type (e-Fatura or e-Arşiv) can then be determined automatically. Manual selection is the most common source of the wrong document type. Embedding this check in the ERP system gives you a single source.
- Tie the mandatory fields to the template. If the mandatory information in Section IV.2.3 and the extra fields for internet sales are required in the invoice template, no document goes out with missing information.
- Monitor transmission and reporting. An end-of-day check can be set up for invoices not delivered to the buyer, with no report generated, or returning an error. These recurring checks are good candidates for automation with RPA.
- Write an outage plan. The exceptions in Section V.7 depend on proof and documentation. Who does what during a system outage, and how the outage is documented, should be defined in advance.
- Put format updates on the calendar. GİB updates the e-Arşiv packages periodically; the year's changes are summarized in our e-Document updates article.
Frequently asked questions
What is an e-Arşiv taxpayer? A taxpayer permitted by GİB to join the e-Arşiv Fatura application. According to GİB's application page, those who join through a private integrator do not need to apply to GİB separately.
If I am an e-Fatura user, do I also have to move to e-Arşiv? Yes. Under Section IV.2.4.1, taxpayers included in the e-Fatura application must also move to e-Arşiv, apart from certain exceptions.
Do I have to print an e-Arşiv invoice on paper? No. Under Section V.5.2, electronic transmission needs no paper printout; it can also be given on paper if the buyer requests it.
If I have not moved to e-Arşiv, can I still issue a paper invoice? From January 1, 2026, invoices of taxpayers not included in e-Arşiv must also be issued as e-Arşiv regardless of the amount. For taxpayers under the simplified procedure and the business-account basis, the date is January 1, 2027.
Conclusion
e-Arşiv Fatura is no longer a matter for particular groups; it concerns almost everyone who issues invoices. The document type is determined by the buyer, and from 2026 the amount threshold is gone as well. Having the system choose the document type, tying the mandatory fields to the template, and monitoring transmission and reporting make this burden predictable. Because the rules can change, follow GİB announcements and confirm your obligations with your certified public accountant.
Why logistics experience matters in e-Arşiv invoicing. Many e-Arşiv invoices are created where goods change hands. A paper invoice handed over with the goods can stand in for an invoice with a dispatch note only if it is issued at the moment of delivery, shows the hour and minute, carries the required statement and is signed; an internet-sale invoice must show the carrier and the dispatch date. These details typically originate on the loading dock and at the shipping desk rather than in accounting, so the outage plan and the end-of-day checks above are best designed with the people who dispatch and deliver the goods. One of Orient Global's consultants brings more than 30 years in operations, logistics and supply chain: at a technology distribution company of roughly one billion dollars in scale, he ran logistics, warehousing, technical service and administrative operations end to end, building and leading teams of 100+ people and delivering lasting gains in operational performance through KPI-driven programs. He has also managed nationwide warehouse and transport operations across leading retail, logistics and distribution organizations. An industrial engineer, he now brings that supply-chain discipline to SMEs through AI and automation. Meet our consultants.
This article is for general information purposes only and does not constitute legal or financial advice. Please consult a specialist about your own situation.
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