"Do we have to switch to e-İrsaliye (the electronic dispatch note), or is e-Fatura (Türkiye's e-invoice system) enough?" This question usually comes up as year-end approaches, when revenue figures become clear, or when a customer asks for an e-İrsaliye to accompany a shipment. The answer is not the same for everyone: e-İrsaliye is mandatory for some taxpayers and optional for others.
In this article, we summarize e-İrsaliye from the current text of VUK (Tax Procedure Law) General Communiqué Serial No. 509, published by GİB (the Turkish Revenue Administration), lay out the transition steps, and focus on how the shipment process can be automated. The invoicing side and reconciliation with e-document data are covered in the e-Fatura and end-to-end digital finance article; here, the subject is only the dispatch note.
A practitioner's note. We read the dispatch note the way a logistics operator does, from the loading dock rather than only from the tax file. Our background is two decades of hands-on logistics leadership: running warehouse and distribution operations in a national multi-site third-party logistics (3PL) network, selling 3PL services to corporate customers, and managing the logistics and warehouse backbone of a large technology distributor.
What is e-İrsaliye?
According to Section IV.3.1 of the communiqué, e-İrsaliye is the electronic issuance of the dispatch note (sevk irsaliyesi), which is otherwise issued on paper, together with its electronic delivery to the recipient, its storage and its presentation. The purpose is to make goods movements traceable electronically. The communiqué also states one important point explicitly: e-İrsaliye is not a new type of document; it has the same legal status as the paper dispatch note.
Section IV.3.3 lists the information that an e-İrsaliye must contain: the issue date and document number, the details of the issuer and the customer (including the delivery address, if different), the type and quantity of the goods carried, and the actual dispatch time in hours and minutes. Section IV.3.4, in turn, gives the recipient the option of an e-İrsaliye Yanıtı (e-İrsaliye Response). Through this response, the recipient can tell the issuer how much of the goods it accepted, the quantity it did not accept, and why.
Is e-İrsaliye mandatory, and who has to switch?
According to Section IV.3.2 of the communiqué, e-İrsaliye is not mandatory for anyone other than the taxpayers listed in Section IV.3.5. Those who want to switch voluntarily must first be included in the e-Fatura application.
Section IV.3.5 lists the groups within the scope of the mandate as follows:
- Persons licensed by EPDK (the Energy Market Regulatory Authority), dealerships included, in respect of goods on the ÖTV (Special Consumption Tax) List (I), and those who manufacture, construct or import goods on ÖTV List (III) or market them as a main dealer/distributor,
- Holders of an operating license/certificate under the Mining Law (Maden Kanunu) and those who produce under contract with them,
- Sugar manufacturers,
- Those who manufacture, import or export iron and steel (customs tariff code GTİP 72) and articles thereof (GTİP 73), except those whose commercial income is determined under the simplified procedure (basit usul),
- Users registered in the Fertilizer Tracking System (Gübre Takip Sistemi),
- Those who trade in fruit and vegetables as commission agents or merchants under Law No. 5957 (on the regulation of fruit and vegetable trade),
- Those registered in the e-Fatura application whose gross sales revenue was 10 million Turkish lira or more in an accounting period of 2021 or later,
- Among those required to switch to the İnşaat Demiri İzleme Sistemi (İDİS, the Construction Rebar Monitoring System), those whose gross sales revenue was 1 million Turkish lira or more in an accounting period of 2024 or later.
Additionally, GİB has the authority to bring into scope taxpayers that it considers risky or that show a low level of tax compliance, regardless of their activity or turnover, by giving written notice and a preparation period of at least three months.
A word of caution: GİB's About e-İrsaliye page still shows the old 25 million threshold; the footnotes of the communiqué state that this threshold was changed by Communiqué Serial No. 535. What to rely on is the current text of the communiqué, available from the e-İrsaliye legislation page. Because thresholds may change in the future, also check GİB's current announcements.
How does the 2026 transition period work?
Section IV.3.6 provides for two separate timelines:
- Those that exceed the revenue threshold must switch to e-İrsaliye from the beginning of the seventh month of the period following the accounting period in which the threshold was exceeded. For a taxpayer whose accounting period is the calendar year, this means July 1, 2026 for those that exceeded the threshold with their 2025 revenue, and July 1, 2027 for those that exceed it with their 2026 revenue.
- Those that fall within scope because of their activity or sector must switch from the beginning of the fourth month following the month in which the conditions are met.
After that date, dispatch notes must be issued as e-İrsaliye and must be received as e-İrsaliye from registered users. According to Section IV.3.7, the penalty provisions of the Tax Procedure Law apply to those who do not switch on time or who issue paper dispatch notes even though e-İrsaliye is mandatory for them. Section V.7 sets out, in limited cases only, the exceptions that allow a return to paper, such as a failure in GİB's or the taxpayer's systems or a failure of the financial seal (mali mühür).
We recommend confirming with your certified public accountant (mali müşavir) which rule your own accounting period and activity fall under.
Transition steps
Section V.1 of the communiqué lists three ways to use the application: the GİB Portal, a private integrator and direct integration. The choice depends on shipment volume and on which system the dispatch note will be generated from. A general order of preparation might look like this:
- Determine the scope. Use revenue and activity data to establish under which rule and from which date the obligation arises.
- Check your e-Fatura registration. Being included in the e-Fatura application is a prerequisite for e-İrsaliye.
- Choose the method. For a small number of shipments, the portal may be sufficient; if the dispatch note needs to come out automatically from the warehouse or ERP system, integration is required.
- Application and testing. Follow the application guide and implementation guidelines at ebelge.gib.gov.tr; run a trial with sample documents before the first live shipment.
- Prepare the team. Put the new flow in writing for the shipping supervisor, the warehouse and the drivers.
e-İrsaliye from a process automation perspective
Section V.5.3 of the communiqué contains the rules that determine the timing of the process: the e-İrsaliye must be issued before the actual shipment of the goods and transmitted to GİB's system, and the vehicle must carry the document's paper printout or electronic display. If the invoice was issued before the dispatch note, the invoice's date and number must be entered on the e-İrsaliye. These rules require embedding the dispatch note in the shipment flow. The points that stand out for automation are:
- Generate the dispatch note from the shipping order. If the type, quantity and delivery address of the goods are already in the order or shipping order, creating the document from that record, rather than retyping it, reduces the risk of error. It is important that the ERP system is the single source here.
- Let the system record the actual dispatch time. Since hours and minutes are mandatory information, tying this field to loading confirmation eliminates manual entry.
- Connect responses to the workflow. When a partial-acceptance or rejection response arrives, a task can be opened automatically for the responsible unit to handle the return, short delivery and invoice correction. According to the communiqué, a rejection response is valid only before the actual shipment.
- Match the dispatch note with the invoice. When the e-İrsaliye and the e-Fatura carry the same order reference, a rule-based comparison of the delivered quantity with the invoiced quantity becomes possible. Which automations pay back first on the finance side is covered in the article on automation in finance processes.
Frequently asked questions
If I use e-Fatura, do I have to switch to e-İrsaliye? Not automatically. According to the communiqué, the obligation arises when one of the activity, sector or revenue rules in Section IV.3.5 applies. Being registered in e-Fatura, however, is the prerequisite for switching to e-İrsaliye.
In which situations is an e-İrsaliye issued? In every situation in which a paper dispatch note would be issued, taxpayers within scope must issue the dispatch note as an e-İrsaliye. It must be issued before the goods are shipped and transmitted to GİB's system.
I'm not within scope; can I switch voluntarily? Yes. Section IV.3.2 of the communiqué states that taxpayers who are registered in e-Fatura and have completed the necessary preparations can be included in the application by applying.
Can a paper dispatch note be issued when a system fails? Section V.7 permits paper issuance in limited cases, such as a failure in GİB's or the taxpayer's systems or a failure of the financial seal. Other reasons attributable to the taxpayer itself do not fall within this scope.
Conclusion
e-İrsaliye is not mandatory for everyone; the obligation arises from the activity, sector and revenue rules, and the transition date varies according to the rule that applies. For a business that is about to fall within scope, the real job is not producing the document electronically but connecting the dispatch note to the same data flow as the shipping order, the warehouse and the invoice. Because the rules can change, it is necessary to follow the current text of the communiqué and GİB announcements, and to verify obligations with a certified public accountant and the legal department.
This article is for general information purposes only and does not constitute legal or financial advice. Consult your own expert for your specific situation.
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