Turkey’s capital markets regulator, the Capital Markets Board (SPK), places significant emphasis on the governance and security of information systems. Under this framework, companies operating in Türkiye’s regulated markets must undergo an Information Systems Independent Audit, conducted by licensed audit firms that comply with strict competency and reporting standards.

The SPK’s Information Systems Independent Audit Introduction Guide clarifies the methodology, scope, and expectations of this audit. For foreign investors, multinational corporations, fintech companies, and financial institutions operating in Türkiye, understanding this regulatory guide is essential for maintaining compliance and reducing operational risk.

Why This Guide Matters for International Companies in Turkey

The Guide reflects Türkiye’s alignment with international assurance practices and sets clear rules for how technology must support financial integrity. Its purpose is to ensure that:

• Information systems are secure, well-controlled, and reliable

• Critical business processes and financial data are supported by robust IT governance

• Regulated entities are audited by professionals with verified technical qualifications

• Senior management maintains oversight of IT risks and internal controls

For foreign companies entering the Turkish market, this guide signals a mature regulatory environment where transparency, accountability, and technology governance are mandatory components of compliance.

Core Components of the SPK Information Systems Independent Audit

1. Scope of the Audit

Auditors evaluate a wide range of infrastructure and governance elements, including:

• Hardware, software, and network architecture

• Cybersecurity controls and access-management structures

• Change-management and incident-response procedures

• Logging, monitoring, and business-continuity arrangements

• Alignment between IT processes and financial reporting

2. Auditor Competency Requirements

Audit professionals must meet minimum training obligations:

• 20 hours of structured training per year

• 80 hours within a rolling 3-year period

This ensures that audit teams remain up-to-date with evolving cybersecurity and information-systems audit standards.

3. Methodology and Reporting

The SPK Guide requires:

• A risk-based audit methodology

• Evidence-based review of controls and documentation

• Clear conclusions on the effectiveness of IT governance

• Reporting to senior management and, when required, the regulator

These standards mirror global IT-audit frameworks, providing comfort to international stakeholders.

4. Governance Responsibilities

The Guide emphasizes that ultimate responsibility rests with the board of directors and senior management, regardless of outsourcing or delegation. Proper oversight must be demonstrable, documented, and integrated into corporate governance.

Implications for Businesses Operating in Turkey

Companies—especially those with cross-border structures—should consider the following:

• Ensure IT governance frameworks comply with SPK standards

• Conduct readiness assessments before the independent audit

• Review internal documentation, cybersecurity practices, and control design

• Choose an audit firm with proven information-systems expertise

• Address audit findings through structured remediation and reporting

For fintech companies, payment institutions, portfolio-management firms, brokerage houses, and other SPK-regulated entities, strict adherence to this Guide is crucial for maintaining regulatory credibility.

How Cindemir Law Assists International Clients

At Cindemir Law, we advise domestic and multinational clients on regulatory compliance under Turkish capital-markets legislation. Our services include:

• Drafting and negotiating audit engagement agreements

• Advising boards and executives on IT-governance responsibilities

• Compliance support under SPK’s Information Systems Management and Audit Communiqués

• Regulatory filings, disclosures, and audit-readiness assessments

• Legal guidance on cybersecurity, data protection, and technology-risk management

• Post-audit remediation planning and compliance reporting

With extensive experience in cross-border regulatory matters, we support clients seeking transparency, stability, and long-term operational continuity in Türkiye.

Conclusion

SPK’s Information Systems Independent Audit Guide forms a vital part of Türkiye’s regulatory infrastructure. It ensures that financial-market participants maintain secure, auditable, and well-governed information systems. By understanding and applying the requirements of this Guide, companies—both local and international—can strengthen compliance, reduce risk, and build confidence among regulators and stakeholders.

Cindemir Law stands ready to support businesses navigating Türkiye’s evolving regulatory environment.