| TAX CIRCULAR: 2026-120 | DATE: 24.10.2026 |
Under Circular No. 2026/22 issued by the Social Security Institution (SGK), procedural principles regarding the allocation of insurance service days and the imposition of administrative fines based on official documents from public authorities and in-person traffic violation notices have been restructured.
Key Operational Principles
1. Audit and Review Authority:
Determinations derived from traffic violation notices delivered in person and official records from public administrations will first be evaluated by the Department for Combating Unregistered Employment (KADIM). Records confirming employment at the identical workplace will be processed by KADIM units, whereas unverified or divergent cases will be transferred to social security inspectors.
2. One Day of Service Credit Per Recorded Date:
For each record identifying actual physical work documented in reports issued by public personnel other than formal audit inspectors (police, gendarmerie, municipal inspectors, physicians, veterinarians, engineers, etc.), 1 day of insured service will be granted to the worker as of the date the report was compiled.
3. Evaluation as Part-Time Employment and Initial Penalty:
Where multiple determinations verify an individual working at the same workplace, the earliest dated record is established as the formal recruitment date. For each confirmed day in the current and subsequent consecutive months, one service day is credited under the legal framework of part-time employment. Accordingly, an administrative fine amounting to 2 gross minimum wages is applied solely for the first recruitment date.
4. Interrupted Periods Treated as Re-employment with Increased Fine:
The first determination following a calendar month with no recorded determinations will be treated as a completely new recruitment. The preceding employment period is terminated by drafting an official dismissal declaration as of the last credited day, and a new employment declaration is ex officio issued on the first day of the subsequent determination. Because this constitutes a repeated non-filing of employment notification within one year, an administrative fine of 5 gross minimum wages will be levied. If the parties file an objection asserting continuous uninterrupted work, the case will be referred to social security inspectors for comprehensive investigation.
