Extension of the Exemption Period for Independent Audit Firms Authorized to Conduct Sustainability Audits
The Public Oversight, Accounting and Auditing Standards Authority (“KGK”) has, by its decision dated 22.09.2025 and numbered 75935942-050.01.04-[01/35554] (“Decision”), enacted a regulation concerning the exemption period for audit teams under the Sustainability Audit Regulation (“Regulation”), which was published in the Official Gazette No. 32785 on 17.01.2025.
Pursuant to Article 18 of the Regulation:
- Sustainability audits shall be carried out by audit teams composed of a number of auditors with the qualifications required for the work,
- Audit teams shall be formed with a sufficient number of auditors who possess the authority, knowledge, skills, and experience to perform the audit in accordance with KGK regulations, taking into account factors such as the size of the audited entity, its activities, applicable regulations, and similar considerations,
- In any case, audit teams shall consist of no fewer than three auditors, including one responsible auditor,
- For the responsible auditor and other designated positions within the audit team, at least one substitute auditor shall be appointed,
- Substitute auditors must be qualified to assume the responsibilities of the positions they replace.
However, Temporary Article 1 of the Regulation introduces an exemption (“Exemption”) from the conditions set out above. Accordingly, for sustainability audits relating to financial periods ending before 01.01.2026, and provided that all other requirements for audit teams under Article 18 are met:
- Audit teams may include auditors who are not authorized in the field of sustainability,
- Nevertheless, it is mandatory that the responsible auditor and at least one other auditor in the main audit team are authorized in the field of sustainability.
With the decision taken by KGK, the validity period of the Exemption has been extended until 01.01.2027. Therefore, for sustainability audits conducted up to 01.01.2027, auditors who are not authorized in the field of sustainability may also be included in the teams. However, the requirement that the responsible auditor and at least one auditor in the team must be authorized in the field of sustainability continues to apply.
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