For an investor relations desk, the morning of 1 October 2026 differs from other mornings in one respect: two texts are open on the screen at once. The board approved a binding asset sale agreement late the night before, the announcement has to go out before the market opens, and the Turkish draft is ready in twenty minutes. What is new is that the English version of that draft has to be finished inside those same twenty minutes. Publishing first and translating afterwards is not an option.
The reason is decision no. 49/1489 of the Capital Markets Board (Sermaye Piyasası Kurulu, SPK), published in Bulletin no. 2026/51 dated 13 August 2026. It amends the section of the Guide on Material Event Disclosures (Özel Durumlar Rehberi) headed “IV. Language and Form of Notification of Material Event Disclosures”, extending the English disclosure obligation to all publicly held companies whose shares are traded on the exchange. Because the text sits in a Board bulletin, a compliance desk that does not read the bulletins could reach the morning of 1 October without noticing the change.
The obligation itself is not new; what is new is its scope. The distinction sounds minor, and it changes everything for a process that has run in one language until now. A second text that must be published simultaneously is not an administrative line added to the compliance calendar. It is a second surface for error resting on what the company tells the market, better handled as a legal risk than a translation errand.
The only thing that changes is scope, and scope changes everything
Under the Guide as it stands, the English disclosure obligation applies to companies in the first group as determined within the framework of the Board’s corporate governance regulations. Those companies make their material event disclosures “in English simultaneously alongside Turkish”. The new decision leaves the predicate of that sentence untouched and changes its subject: the wording now covers all publicly held companies traded on the exchange. The content, form and timing of the obligation stay as they are, and the set of companies bound by it widens.
The effective date is 1 October 2026. Until then, the existing arrangement continues for companies in the first group as determined within the scope currently applied. The calendar therefore falls into two parts. Nothing changes between today and 1 October, and for that reason this interval is the only time set aside for preparation. For a company coming within scope, the effective date is not the day the process is built but the day it must already work.
That the change was made in the Guide deserves attention. The Guide sets out how Communiqué no. II-15.1 on Material Events (Özel Durumlar Tebliği) is applied: when and in what form a disclosure is made sits in the Communiqué, the language provisions in the Guide. If the English version of a disclosure made through the Public Disclosure Platform (Kamuyu Aydınlatma Platformu, KAP) is late or incomplete, the defect does not stay a linguistic one. It raises the question whether the disclosure obligation was properly discharged.
How many hours does “simultaneous” actually leave?
The Guide requires disclosures to be made “immediately”. That principle grants the English text no calendar of its own. Simultaneous means the English disclosure goes out at the same moment as the Turkish one, not after it. The time for translation is therefore not an extra period beginning once the announcement has been drafted, it runs alongside it. That the Turkish drafter and the English drafter receive the same information at the same moment is a requirement of the obligation, not a working convenience.
To see where the time tightens, two ends of the Guide have to be read together. Disclosures falling within articles 12 and 22 of the Communiqué are announced on KAP by 09:00 at the latest on the third business day following the day the situation arises. Transactions of persons discharging managerial responsibilities and of persons closely associated with them, by contrast, are disclosed the moment they arise or come to be known. The gap between those two regimes decides how much time the translating desk really has.
In the second case, the time for translation is limited to the minutes between the notification reaching the desk and the disclosure going out. When a board member’s transaction becomes known on a Friday evening, waiting until Monday morning to write the English text is not an option. The 09:00 deadline on the third business day looks comfortable, yet it covers the whole exercise. Once the legal characterisation, the approval chain and the completion of the KAP form are subtracted, the share left for translation is narrow, and its last minutes tend to fall outside office hours.
What the reservation notice settles, and what it does not
The Guide requires the English disclosure to carry a reservation notice stating that the Turkish disclosure is to be taken as the operative text. That entry does useful work: it shows which text prevails if a dispute over interpretation arises. In the same place, the Guide states that responsibility for the accuracy of the content remains with the company concerned. The reservation notice settles which text governs. It does not remove the consequences of giving inaccurate or incomplete information.
In practice the distinction looks like this. Where the Turkish text says bağlı ortaklık, a subsidiary, and the English text speaks instead of a participation, the choice is not editorial, it discloses a different fact. If the difference between “the agreement has been signed” and “agreement in principle has been reached” does not survive into English, two investors reading the two texts understand two different stages of one transaction. An investor’s information rights are not confined to the Turkish text. For a reader who takes a position on the English version, what the company disclosed is what that version says.
Consistency of terminology is therefore a legal question rather than a technical one. Translating the same concept with the same term every time lets successive announcements be read against one another. A concept whose English rendering shifts from one disclosure to the next tells the reader that something has changed, even where no sentence is wrong. On a continuing matter, an acquisition still in progress, that impression becomes the subject of an argument about misleading information. The glossary belongs with the legal team for that reason: which rendering to choose depends on what the concept means in Turkish law.
The process to be built before 1 October
What preparation should produce is not a translation budget but a written flow. Who translates, who approves and who publishes has to be settled before the first real disclosure. The five headings below are the minimum questions to answer in writing.
- Separating drafter from approver. The person who prepares the English text should not approve it. Approval should sit on the same line of responsibility as the sign-off on the Turkish disclosure.
- Out-of-hours rota. The immediate disclosure principle draws no distinction between evenings, weekends and public holidays. A rota with named alternates should cover whoever writes and approves the English text.
- Templates and a term glossary. Pre-approved English templates should exist for recurring disclosure types. A glossary fixing one rendering for each company-specific concept removes wording decisions taken at midnight.
- The limits of machine translation. Automated translation earns its place in speeding up a first draft of routine text that fits a template. For sentences carrying a legal characterisation, a condition or a stage of negotiation, it should not reach publication without human approval.
- Forms, archive and version records. Notifications are made using the relevant forms on KAP, with every field completed in full. Each disclosure’s final Turkish and English texts should be kept with their approval chain so both can be traced afterwards.
Running this flow as a dry exercise before 1 October is worth more than any item on that list. Take a handful of disclosures made over the past year, produce them again through the new process, and the gaps in the glossary and the breaks in the approval chain surface at a desk rather than under the pressure of a live announcement. The rehearsal should be written up too: how long each step took, where the drafting stalled, which concept had no settled rendering.
Does this concern only the companies newly brought within scope?
The decision is addressed to publicly held companies traded on the exchange. Its effect reaches a wider circle, and part of that circle should prepare before 1 October.
- Companies newly within scope. For a company that has disclosed only in Turkish, this is a new internal process, not a translation line item. What has to be built is not a text but the chain that produces and approves one.
- Companies preparing for an initial public offering. Building the disclosure regime bilingually from the outset costs less than converting a single-language habit after listing. Headcount and templates should be planned on that assumption.
- Funds with foreign limited partners. For a fund holding listed shares, an English disclosure is no longer a document assembled at reporting time but data arriving with the original. A fund’s own reporting calendar can be rebuilt around that.
- Investors holding shares in listed companies. Seen from the standpoint of minority shareholder rights, the English text is now a regular source. An inconsistency between the two versions turns into a concrete question to put to the company.
Translation now belongs to the issuer’s compliance function
The summary is short. From 1 October 2026, material event disclosures of publicly held companies traded on the exchange will be made in English simultaneously alongside Turkish, the English text will carry a reservation notice stating that the Turkish disclosure is the operative one, and responsibility for the accuracy of the content will remain with the company. The time until then is not for choosing a translation supplier but for putting in writing who writes what and when, and who approves it. The public disclosure regime built on the Capital Markets Law no. 6362 asks that an announcement be accurate as much as timely, and after 1 October that test applies to two texts rather than one.
Source. The SPK’s Bulletin no. 2026/51 dated 13 August 2026 and the Guide on Material Event Disclosures (Özel Durumlar Rehberi) as in force.
This article is provided for general information only and does not constitute legal advice. Please seek legal support for an assessment of any specific matter.
Author
If this is on your desk
Templates and checklists are free in the Founder Academy; for a specific situation, book a 30-minute intro call.
Founder AcademyBook an intro callMore from Vircon Insights
The CASP Licence in Türkiye: An Application Guide in Build Order (Law 7518 / CMB III-35/B.1)
August 4, 2026AI Due Diligence: The Ten Questions Investors Now Ask, and Founders Should Answer Before the Term Sheet
July 29, 2026Your Users Are Younger Than Your Terms Say: Children, Age Assurance and AI Products
August 31, 2026Will Insurance Pay When the Model Is Wrong? E&O, Cyber and Product Liability for AI Companies
August 28, 2026The 40-Question Email That Stalls Enterprise Deals: Answering AI Vendor Assessments Without Overpromising
August 27, 2026Whose Voice Is It Anyway? Voice Cloning Under Turkish Personality Rights, KVKK Biometrics and FSEK
August 26, 2026Related Practice Areas
Corporate Law
Share transfers, capital increases, board structuring, governance.
View service →US Company Formations & Flip-Ups
Delaware C-Corp, flip-up structures, SAFE/convertible notes, 83(b).
View service →Mergers & Acquisitions
End-to-end M&A: due diligence, structuring, documentation, negotiation.
View service →