Why a foreign employer should read the bordro at all
The ücret bordrosu, the payroll payslip, is not an internal accounting note in Turkey. It is one document that the labour inspectorate, the tax office and SGK (social security) all read at the same time. A mistake on the slip is visible to all three. So the question is not how to format it, but which fields must be present so that all three systems read the same thing.
For a foreign employer with staff in Turkey the working test is simple: the payslip, the bank credit and the MUHSGK filing must describe the same person and the same month. When the three files disagree, the discrepancy is found quickly, and not by an auditor but by the system.
What the Labour Code requires
Labour Law 4857 obliges the employer to issue a signed payslip (pusula) with every payment. The minimum field set:
- payment date and pay period;
- all add-ons itemised line by line: overtime, weekend and public holiday work, each as a separate line, never as a lumped other amount;
- all deductions itemised: tax, insurance premiums, advances, nafaka (alimony) and court enforcement deductions (icra).
Overtime and holiday pay collapsed into one allowance line is already a formal breach. The inspector does not need to prove anything: the slip itself shows the calculation was not itemised.
What SGK requires
The monthly payroll document for SGK must contain:
- the workplace registration number (işyeri sicil numarası);
- the accrual month;
- the worker name and SGK number;
- the number of paid days;
- the rate and the amount paid;
- the worker acknowledgement of receipt.
Paid days and the contribution base are exactly what SGK cross-checks against the bank and the filing automatically.
The tax layer: VUK 213 and GVK 193
The Tax Procedure Code (VUK 213) and the Income Tax Law (GVK 193) require the slip to show: the month in the header, the worker name, a receipt mark, the unit rate, the period, the tax on the wage and the withholding visible on the slip itself. Tax kept somewhere in the accountant system does not count: the withholding must be readable on the document.
Employer identity: TTK 6102
The Commercial Code (TTK 6102) adds the corporate block: trade registry number, MERSİS number, trade name, head office address and the registered website where registration is required. For a Turkish subsidiary of a foreign group these are the fields banks and counterparties verify against the registry. A name mismatch between the bordro and the registry is a common trigger for the question of who the employer actually is.
Obligations: TBK 6098 and hesap özeti
The Code of Obligations (TBK 6098) requires a hesap özeti, an account summary: the amount and the reason for every deduction. Writing advance as a single line without amount and date is not acceptable: every deduction needs its amount and its cause.
Bank payment: the threshold dropped to three employees
Since 1 July 2025, under the rule published in the Official Gazette of 4 June 2025, number 32920, employers with three or more employees must pay wages through a bank. The threshold used to be five employees and was cut to three nationwide. Cash payment with three employees on staff is a finable event on its own, regardless of whether the calculation was correct.
The working figure for the 2026 Labour Law fine is around TRY 2734 per worker per month. The figure is indexed every year and must be rechecked at the date of any inspection, not memorised.
Separately: the tax side can also force non-cash payment based on the amount paid, even below three employees. That rule does not depend on the labour threshold, so having only two staff does not close the question by itself.
MUHSGK: one filing instead of two
MUHSGK is the combined declaration: wage withholding tax and SGK service information for staff are filed in a single form. For the employer this means any gap between payroll tax and contributions is visible inside one document. Previously a mismatch between two separate declarations could go unnoticed; now both sit in the same filing.
The three-file test
A practical check worth running every month before payday:
- payslip: the person, the month, the days, the net amount;
- bank: the same person, the same amount, the same month, paid through a bank;
- MUHSGK: the same person, the same days, the same base.
When the three files match, the inspectorate, the tax office and SGK have almost nothing left to ask. When they diverge, the divergence will surface at the next automatic cross-check, not at an audit a year later.
Common questions
Can we pay cash with only two employees?
Under the labour threshold, yes: the bank rule applies from three. But the tax office can require non-cash payment based on the amount even with fewer staff, so a cash decision needs checking against both layers.
Is a standard payroll software printout enough?
Only if it carries every mandatory field: a signed slip with date and period, itemised add-ons and deductions, the employer identity block required by the Commercial Code, the hesap özeti summary and the worker acknowledgement. Most standard templates need manual adjustment.
What happens if the payslip and MUHSGK disagree?
The mismatch is visible automatically, because tax and contributions now live in one declaration. What usually follows is a request for explanation or an assessment on the side with the higher base.
Is TRY 2734 the exact fine?
It is a working figure for 2026. Fine amounts are indexed annually, so the current number should be rechecked before any payment or dispute.
This material is informational and is not individual advice.