Employee Numbers and Financial Thresholds for Mandatory VERBİS Registration in 2026
There are two main criteria that companies confuse most when evaluating the VERBIS registration requirement: annual employee count and annual balance sheet total. As of 2026 in particular, many…
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⏱️ Reading time: 10 min · 📁 Category: KVKK, Digital Compliance and Data Security
Employee Count and Balance Sheet Criteria for Mandatory VERBİS Registration
There are two main criteria that companies confuse most when evaluating the VERBIS registration requirement:
annual employee count and annual balance sheet total.
As of 2026 in particular, many companies with few employees may fall within
the obligation to register with VERBİS because of the balance sheet criterion.
VERBİS obligations should therefore not be assessed solely by asking “How many employees do we have?”
The company’s balance sheet total, main business activity, processing of special categories of personal data and status as a data controller must be analyzed together.
In a general assessment, data controllers with an annual employee count exceeding 50 or
an annual balance sheet total of TRY 100 million or more should be examined
specifically for the VERBİS registration requirement.
Lower thresholds may apply to data controllers whose main activity is processing special categories of personal data.
What Is the VERBİS Registration Requirement?
VERBİS, the Data Controllers Registry Information System, is the official system through which controllers declare their personal data processing activities
to the Authority.
During VERBİS registration, the data controller reports which personal data it processes, the purposes of use,
the recipients and retention periods through the system.
Therefore, VERBIS is not just a technical registration process.
It is an obligation that makes the company's KVKK compliance level visible, records data processing processes, and increases auditability.
One of the best-known criteria for mandatory VERBİS registration is the annual employee count.
In general practice, data controllers with more than 50 employees annually should be assessed for VERBİS obligations.
The employee count at a single point in time is not the only consideration.
The company's employment structure during the year, the number of employees with payroll, and year-based employee average should be taken into account together.
- Number of employees per year: 62
- Annual balance sheet total: TRY 40 million
In this example, even though the balance sheet total is below TRY 100 million,
the company’s VERBİS registration obligation must be assessed because of its employee count.
The employee count and balance sheet criteria do not both have to be met in most cases.
Exceeding either criterion requires a separate assessment of VERBİS obligations.
The second important criterion in the VERBIS registration requirement is the annual financial balance sheet sum.
In the 2026 assessment, balance sheet data, particularly attached to the 2025 corporate tax return, became critical.
For data controllers whose main activity is not processing special categories of personal data,
a balance sheet total of TRY 100 million or more must generally be considered when assessing mandatory VERBİS registration.
- Number of employees per year: 28
- Annual balance sheet total: TRY 135 million
In this example, even with fewer than 50 employees, the balance sheet total is at least TRY 100 million, so
a VERBİS registration obligation may arise.
For the balance sheet criterion, turnover and balance sheet total are not the same.
The relevant amount for VERBİS is the balance sheet total shown in the balance sheet attached to the tax return for the year concerned.
A common mistake is assuming that both more than 50 employees and a TRY 100 million balance sheet total are required.
In VERBİS assessments, these criteria are usually considered as alternatives.
A company with few employees but a high balance sheet total, or a low balance sheet total but many employees,
may therefore have to register with VERBİS.
- More than 50 employees + low balance sheet total: VERBİS obligations may arise.
- Fewer than 50 employees + balance sheet total of TRY 100 million or more: VERBİS obligations may arise.
- Fewer than 50 employees + balance sheet total below TRY 100 million: an exemption assessment may be possible.
- Main activity involving special categories of personal data: lower thresholds should also be examined.
For some data controllers, an assessment is made different from the general 50 employees and $100 million balance sheet criterion.
Businesses whose main activity is processing special categories of personal data in particular require a more careful analysis of their obligations.
Institutions that process health, biometric, genetic, criminal conviction or other special-category data at the core of their main activity
may become subject to VERBİS obligations at lower thresholds.
- Private hospitals, clinics and outpatient clinics
- Laboratories
- Health tourism companies
- Businesses that use biometric data
- Genetic testing and analysis services
- Digital platforms processing large volumes of health data
The company’s balance sheet total becomes clear after filing the corporate tax return.
Therefore, April and May in particular are critical periods in terms of VERBIS registration requirement.
Companies becoming subject to VERBİS for the first time because of their balance sheet total must complete registration and notifications
within the prescribed period, calculated from when the obligation arises.
For legal-person data controllers subject to corporate tax whose balance sheet totals exceed the relevant thresholds after the 2025 corporate tax return,
the registration deadline in 2026 must be tracked separately.
VERBİS obligation analysis must go beyond accounting or human resources data alone.
Financial, administrative and legal data must be examined together for correct assessment.
- Number of employees per year
- Annual financial balance sheet total
- The company's main activity
- Whether special categories of personal data are processed
- Data processing volume
- Whether there is data transfer abroad
- Continuity of data processing activities
Thresholds alone are not enough to determine VERBİS obligations.
Along with threshold analysis, data processing inventory, retention times, transfer processes and technical/administrative measures should also be reviewed.
Failure to meet the VERBİS registration obligation may result in an administrative fine under KVKK.
In addition to this, incomplete, inaccurate or non-current VERBIS notifications also pose risks.
It is not enough for companies to simply say "we have registered".
The VERBIS statement must be consistent with the company's actual data processing activities.
- Failure to register with VERBİS when required
- Missing data category notification
- Statement of incorrect retention period
- Incomplete disclosure of overseas transfer processes
- Mismatch between the data inventory and VERBİS registration
The number of employees and financial balance sheet requirements for the VERBIS registration requirement are two main criteria that must be evaluated together.
However, this assessment is not just about numerical thresholds.
In 2026, companies must analyze together the 50-employee threshold, the TRY 100 million balance sheet criterion,
special-category personal data processing and the 30-day registration period.
VERBİS obligations must therefore be checked after year-end financial statements and corporate tax returns.
Faulty or late assessments can pose both an administrative fine and a risk of a lack of KVKK compliance.
At B10 Digital Agency, we assess employee count, balance sheet total, main activity and data processing together
to determine whether your company must register with VERBİS.
Our hybrid model brings legal advisers and technical teams together,
covering VERBİS registration as well as the data inventory, retention and destruction policy, privacy notices and a sustainable KVKK compliance framework.
The number of employees, financial balance sheet and activity are examined together. 📋 VERBIS Preparation
Data inventory, retention times and data categories are prepared. ⚖️ KVKK Compliance Plan
privacy notice, destruction policy, and technical/administrative measures are reviewed.
If your company’s employee count or balance sheet total approaches VERBİS thresholds, analyze the obligations without delay.
Get a VERBİS Obligation Analysis
No. These criteria are usually alternatives. Exceeding either the employee count or balance sheet criterion requires an obligation analysis.
Can a Company with Fewer Than 50 Employees Have to Register with VERBİS?Yes. Even with fewer than 50 employees, a VERBİS registration obligation may arise if the annual balance sheet total exceeds the relevant threshold.
Is the financial balance sheet sum or turnover taken into account?The criteria that are taken into account in the VERBIS assessment are not turnover, but financial balance sheet sum of the relevant year.
Is the Threshold Different for Special-Category Personal Data Processing?Yes. Data controllers whose main activity is processing special categories of personal data may face lower thresholds and require a more careful assessment.
Sources and related documents
These documents provide references for the methods and rules discussed in this article.