"Who will keep track of electronic notifications (e-Tebligat), and how do we automatically route an incoming notification so that we don't miss the deadline?" In companies where letters from the tax administration land in a digital system rather than in a mailbox, this question is a shared agenda item for the finance and legal teams.
The reason this question is pressing now is clear. Article 9 of Law No. 7587, published in the Resmî Gazete (Türkiye's Official Gazette) of 1 July 2026, rewrote Article 107/A of the Tax Procedure Law (Vergi Usul Kanunu, VUK). The new text names, directly in the statute, the persons who must use the electronic notification system, and it states explicitly on which day service (tebliğ) is deemed to have been made. According to the Law's entry-into-force article, this provision came into force on the date of its publication.
What does the Law say?
Under the new Article 107/A, those required to use the electronic notification system established by the Ministry of Treasury and Finance (Hazine ve Maliye Bakanlığı) are:
- taxpayers subject to corporate tax,
- income taxpayers taxed under the actual-basis method (gerçek usul) on their commercial, agricultural and professional earnings,
- general partnerships (kollektif şirket) and ordinary limited partnerships (adi komandit şirket),
- natural and legal persons in whose name registration is made upon the first acquisition of goods subject to recording and registration listed in List (II) annexed to the Special Consumption Tax Law (Özel Tüketim Vergisi Kanunu), as well as entities without legal personality.
These persons can be served electronically through the system, without being bound by the procedures in Article 93 of the VUK. Those outside the scope can join the system on request; for people with a disability rate of 90% or higher, there is no obligation. Legal entities registered with the trade registry, in turn, are removed from the system by reference to the date their registry record is deleted.
From an operational standpoint, the most critical sentence concerns timing: an electronic notification is deemed made at the end of the fifth day following the date it was delivered to the addressee. The text does not tie the moment of service to the document being opened or read. In other words, even if nobody looks at the document, it is deemed served at the end of five days, and the time limits that depend on it begin to run.
Provisional Article 38, added to the Law, also concerns existing users: those who were in the system before that date continue to use it without making a new application. So for existing users, the issue that stands out is not a new application but monitoring discipline.
Why does the deadline matter so much?
Documents that arrive through electronic notification are not ordinary informational letters. The information note that GİB (the Turkish Revenue Administration) prepared in February 2025, before the change in the law, lists payment orders, assessment notices (ihbarname) and letters on deficiencies in VAT refund requests among the documents sent through the system. The same note states that administrative fine records from certain institutions that have signed a protocol, as well as consumer arbitration committee and customs letters, can also arrive through this channel, and that the documents will not additionally be sent by post.
Some of these documents set objection and litigation periods running. Under the Administrative Procedure Law (İdari Yargılama Usulü Kanunu), unless a special law sets a separate period, the time limit for filing a lawsuit in tax courts is thirty days; where notification has been made, this period starts on the day following the notification. When the five-day service period is considered together with the statutory period that follows it, checking the system once a week becomes a risky habit.
Not one channel but two electronic addresses
One more point is easily overlooked when drawing up a tracking plan. While GİB's system is used for tax notifications, Article 7/a of the Notification Law (Tebligat Kanunu) also makes electronic notification mandatory for all private-law legal entities, including those established by law. These notifications are carried out through the Ulusal Elektronik Tebligat Sistemi (National Electronic Notification System), set up and operated by PTT (the Turkish postal service). Under this law as well, an electronic notification is deemed made at the end of the fifth day following the date it reaches the addressee's electronic address.
In practice, a company can have at least two separate electronic notification mailboxes, and both work on the same five-day logic. When responsibility for monitoring is left only to accounting or only to the legal department, the other channel can end up with no owner.
A practical path: the tracking and routing flow
The steps below are a general framework derived from the text of the legislation; each organization needs to adapt it to its own structure and to the opinion of its legal department.
- Build a channel inventory. For every legal entity in the group, collect in a single table which electronic notification addresses exist, who has access authority, and who the backup person is.
- Define ownership. Assign one responsible person and one backup for each channel. Set a written rule under which access is handed over without interruption in case of leave, illness or departure.
- Make the daily check a routine. With a five-day period, checks need to take place at least on a business-day basis. Because it is repetitive and rule-based, this step is one of the best suited to automation.
- Collect with a bot, decide with a person. If the system has no integration interface, an RPA bot can log in at a set time every day, list new records, download the document to the archive and enter the record in the notification tracking table. Decisions on objections, payments or lawsuits should always remain with the authorized person.
- Calculate dates automatically. For each record, keep the delivery date, the date on which service is deemed made and the statutory time limit to be flagged by the relevant unit in the same row. The rules for calculating the time limit should be written together with the legal department; the bot should only apply these rules.
- Route by document type. Payment orders and assessment notices should go to legal and finance, VAT refund deficiency letters to the tax team, and customs letters to the foreign trade unit. Routing can be done through email, a task management tool or a workflow system.
- Set an escalation rule. Records that do not receive a "seen" mark within a given time should be automatically reported to a more senior manager.
- Secure the access. The credentials the bot uses should be kept in a password vault, its permissions should be limited to reading and downloading only, and every action should be logged.
- Leave an audit trail. A record showing which document was received when, to whom it was routed and who took action is valuable both for internal audit and for a possible dispute.
This flow is a natural part of the digital finance structure that began with e-invoicing and e-transformation. It can be read together with our e-transformation article, which covers the topic in a broader frame.
Conclusion
VUK Article 107/A, as rewritten by Law No. 7587, spells out in the text of the statute who must use electronic notification and that service will be deemed made at the end of the fifth day. Taking the obligation in the Notification Law into account as well, the real question for companies is no longer registering with the system but making sure that every incoming document reaches the right person on time. For that, establishing ownership and a channel inventory first, and then connecting the daily collection, date calculation and routing steps to automation, can be a sound starting point.
Why logistics experience matters here. The nine steps above will look familiar to anyone who has run inbound operations: an inventory of receiving points, a named owner and a backup for each, a daily check, routing by document type, escalation when nothing is acknowledged, and a record of who handled what and when. The difference is that what arrives is a legal document with a deemed-service clock already running, and for a business that moves goods across borders, customs letters are among the documents that can arrive through this channel. 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.
This article is for general information purposes only and does not replace legal advice.
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