Invoice Special Irregularity Penalties 2026

In 2026, the special irregularity penalty for not issuing or not receiving an invoice is 10% of the document amount for each document. However, this amount cannot fall below the minimum amounts, which start at 17,000 TL and rise to 170,000 TL depending on the detection order. The total penalty imposed for this reason in a calendar year cannot exceed 17,000,000 TL for each document type.

In this article, we present the 2026 amounts under Articles 353/1 and 353/2 of the Tax Procedure Law (VUK) in tables that compare them with the 2025 amounts, and we show with examples how the penalty is calculated.

What is the special irregularity penalty, and when is it imposed?

The special irregularity penalty is set out in Article 353 of the Tax Procedure Law and applies when documentation rules are not followed. Whether there is a tax loss is irrelevant; simply not issuing or not receiving a document is enough for the penalty to be imposed. The article contains two separate paragraphs.

353/1 — invoices and similar documents: Not issuing or not receiving an invoice, expense voucher (gider pusulası), producer receipt (müstahsil makbuzu) or self-employment receipt (serbest meslek makbuzu). The penalty can be imposed both on the seller who does not issue the document and on the buyer who does not receive it.

353/2 — receipts and dispatch notes: Not issuing or not receiving documents such as retail sales receipts, cash register (ÖKC) receipts and dispatch notes (including e-dispatch notes, or e-İrsaliye).

The table below summarizes which document falls under which paragraph:

Fixed amounts are updated every year by the revaluation rate. The revaluation rate for 2025 was set at 25.49% by VUK General Communiqué No. 585; the 2026 amounts were updated on the basis of this rate by Communiqué No. 588.

2026 special irregularity penalty amounts (VUK 353/1)

Under 353/1, the penalty is whichever is higher: 10% of the document amount or the minimum amount set according to the detection order. The table below shows the 2026 amounts alongside the previous year's (2025) amounts.

The minimum amount applies to each document separately. If more than one sale without an invoice comes to light in the same detection, the minimum amount for that detection order is applied to each of them.

VUK 353/2: penalties for receipts and dispatch notes

For documents under 353/2, the penalty is calculated separately for each document and, in 2026, ranges from 17,000 TL to 170,000 TL depending on the detection order. This paragraph also sets a cap for each detection.

For marketplace sellers, the most important item under 353/2 is the dispatch note. If you move goods to another location without an invoice (e.g., from warehouse to warehouse or to a fulfillment center), you need to issue a dispatch note. You can check whether you are an e-dispatch note taxpayer in our article on the e-dispatch note requirement.

How is the special irregularity penalty calculated? Examples

To calculate it, you only need to answer two questions: what is 10% of the document amount in TL, and what is the minimum amount for that detection order? The penalty is the higher of the two. The amounts below are chosen as examples.

Example 1: Suppose that at the first detection it is found that a 40,000 TL sale was made without an invoice. In this example, 10% is 4,000 TL; since this is below the 17,000 TL minimum, the penalty is 17,000 TL. For small sales, the minimum amount is decisive.

Example 2: Suppose a 250,000 TL wholesale sale was made without an invoice; 10% is 25,000 TL. Since this is higher than the minimum for the first detection, the penalty is 25,000 TL.

Example 3: Suppose that at the second detection it is found that a 120,000 TL sale was made without an invoice. In this example, 10% is 12,000 TL; since this is below the 35,000 TL minimum for the second detection, the penalty is 35,000 TL. Because the minimum rises as the detection order advances, the same mistake becomes more expensive.

Example 4: Suppose that at the first detection it is found that 3 separate sales of 30,000 TL each were made without invoices. 10% of each is 3,000 TL; since this is below the 17,000 TL minimum, a 17,000 TL penalty is calculated for each document, for a total penalty of 51,000 TL. Because every marketplace order requires a separate invoice, the number of orders with a forgotten invoice directly multiplies the penalty.

Marketplace scenario: invoices missed during a campaign week

Suppose that during a campaign week, invoices were not issued for 12 orders because of an integration error, and each order is worth around 1,500 TL. In this example, 10% of each order is 150 TL, far below the minimum for the first detection. So 17,000 TL is calculated for each order, and the total penalty reaches 204,000 TL. Because the minimum amount applies to small orders, the penalty can exceed the sales amount many times over.

This scenario shows why daily invoice checks matter: if you spot a missed invoice and issue it before 7 days have passed since delivery, the document counts as issued on time.

How does the annual cap work?

The annual cap applies to the total of penalties imposed for the same reason within a calendar year and is 17,000,000 TL for each document type in 2026. Small and medium-sized sellers rarely reach this cap; it mostly comes into play when a large number of undocumented transactions are detected all at once.

Matters such as settlement (uzlaşma), penalty reductions or which periods count toward the detection order vary depending on the specific case; confirm these points with your certified public accountant (mali müşavir).

You are also at risk as a buyer

The special irregularity penalty does not concern only the sales side. Because 353/1 also covers not receiving documents, missing documents on a marketplace seller's purchasing side also create risk:

• Buying goods from a supplier without an invoice: For the seller, products bought from a wholesaler or manufacturer without an invoice mean both the risk of not receiving a document and the loss of expense and VAT (KDV) deductions.
• Not getting documents for services: If you buy services such as product photography, product description writing or ad management from self-employed professionals, get a self-employment receipt or an invoice.
• Not tracking marketplace invoices: Marketplaces issue invoices for commissions, service fees, shipping and advertising. Checking that these invoices reach you in full is necessary both for your expense records and for your documentation.

From 2025 to 2026, the minimum amounts increased by roughly the revaluation rate; the minimum for the first detection rose from 14,000 TL to 17,000 TL. Since the amounts are updated every year, make sure you use the amounts for the year in which the document should have been issued when calculating the penalty.

Paper invoice = invoice never issued

If a paper invoice is issued while the e-document (e-Belge) requirement applies, the document is treated as never issued, and a separate VUK 353 penalty applies to each paper document. In other words, a seller who should have switched to e-archive invoices (e-Arşiv) and gives a customer a paper invoice faces the same penalty consequences as if no invoice had been issued at all.

In 2026, taxpayers other than those under the simplified method (basit usul) or the business account basis (işletme hesabı) must issue all their invoices as e-Arşiv, regardless of amount; for taxpayers under the simplified method or business account basis, invoices exceeding 3,000 TL including taxes must be e-Arşiv. We explain who is covered in our article on the e-archive invoice requirement.

The same result applies to invoices not issued on time: if an invoice is not issued within 7 days of the delivery date at the latest, it is treated as never issued. For details, see our article how many days you have to issue an invoice.

Risk points for marketplace sellers

• Orders without invoices: Orders missed because of integration errors, cancel-and-reorder confusion or the campaign rush.
• Late invoices: Invoices issued after more than 7 days are treated as never issued.
• Paper documents instead of e-documents: Continuing to use paper invoices after the e-invoice (e-Fatura) or e-Arşiv requirement has started.
• Forgetting the expense voucher on returns: The expense voucher is also covered by 353/1; if you do not issue a document for a consumer return, this can also lead to a penalty. See expense voucher for consumer returns.
• Undocumented movement of goods: Shipping to a fulfillment warehouse or another warehouse without an invoice or dispatch note.

Checklist to avoid penalties

1. Every day, compare your marketplace order list with your list of issued invoices.
2. Do not leave any order without an invoice once 7 days have passed since delivery.
3. Track your e-Fatura and e-Arşiv transition dates, and retire your paper invoice books.
4. Make sure there is an expense voucher or return invoice for every return.
5. Issue a dispatch note for every shipment of goods made without an invoice.