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ARTICLE · 12 JANUARY 2026

Financial Thresholds Under IPO Requirements Updated For 2026

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With the decision of the Capital Markets Board of Türkiye (the "CMB") dated 31 December 2025 and numbered 2025/68 (the "Decision")...

TurkeyFinance and Banking

With the decision of the Capital Markets Board of Türkiye (the "CMB") dated 31 December 2025 and numbered 2025/68 (the "Decision"), the financial thresholds required to be met for initial public offering ("IPO") applications to be filed in 2026 by companies whose shares will be offered to the public for the first time have been tightened.

The Decision introduces the following changes:

a) Pursuant to Article 5 of the Communiqué on Shares (VII-128.1); the underwriting liability of intermediary institutions, calculated based on the market value of the shares to be offered to the public (excluding any over-allotment), as determined by the IPO price, has been revised as follows:

i. if such market value is below TRY 750,000,000, the intermediary institution underwrites the entirety of the unsold shares,

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