Understanding SPK’s Introduction Guide for Information Systems Independent Audit

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In today’s digital age, companies operating in regulated markets are increasingly reliant on robust information systems. For entities subject to audit oversight by the Sermaye Piyasası Kurulu (SPK), ensuring that their IT infrastructure, controls and governance are aligned with regulatory standards is critical. One key document in this area is SPK’s “Bilgi Sistemleri Bağımsız Denetimi Tanıtım Rehberi” (Information Systems Independent Audit Introduction Guide) — a reference guide that helps independent audit firms and regulated institutions understand the scope, methodology and expectations of independent information-systems audit.

Why this Guide Matters

The Guide emphasises that independent audit firms appointed by SPK-authorised entities must ensure that the personnel engaged in information systems audits meet certain training and competency thresholds — for example, each person must complete at least 20 hours of continuing education per year and at least 80 hours in a 3-year rolling period. SPK
The Guide also links to broader regulatory frameworks that address information-systems governance, management and auditable controls (notably the SPK “Information Systems Management Communiqué” (VII-128.9) and “Information Systems Independent Audit Communiqué” (III-62.2)). procompliance.net+1
For Turkish and foreign-investor clients alike, the Guide represents part of the transparency framework, signalling to stakeholders — including financial regulators, independent auditors and corporate boards — that information-technology risks are being assessed by qualified parties and subject to independent verification.

Key Scope and Provisions

Based on the Guide and the related SPK communiqués, the following are among the major areas of focus:

  • Audit subject matter: The independent audit of information systems covers not only hardware, software and network infrastructure, but also the systems and processes through which those technology components support business-processes, financial reporting, internal control, and regulatory compliance.

  • Competency requirements: Audit firms must deploy staff with relevant experience in information systems, audit standards and technology controls. Continuing education and documented hours are required. SPK+1

  • Audit methodology and reporting: The Guide explains that audits must follow methods consistent with international information-systems auditing standards, risk-based approaches, sampling techniques and sufficient evidence gathering. Audit reports must express a conclusion on whether the entity’s information systems governance and controls — as of a specific date — are operating effectively in accordance with the applicable standards. procompliance.net+1

  • Regulated entities: While the communiqués initially focused on banking and financial-sector institutions, the guidance now extends (or may extend) to other firms in the capital-markets domain subject to SPK oversight. procompliance.net+1

  • Governance and alignment: A key theme is that information systems should not be a standalone IT silo but aligned with business strategy, value creation and risk management. Boards of directors and senior management retain accountability for setting the tone and oversight. spl.com.tr

Practical Implications for Clients and Auditors

For a law firm advising clients in Turkey’s capital markets, the Guide highlights several practical considerations:

  1. Engagement with IT-audit readiness
    Companies subject to information systems independent audit should begin by assessing their current IT-governance framework: Are roles/responsibilities defined? Is there documented strategy linking technology to business objectives? Are controls defined for key systems and risks? The cited training material emphasises such “strategy to value” linkage. spl.com.tr

  2. Choosing and overseeing the audit firm
    The selection of an independent audit firm (or an audit-team) with the right skillset is essential. Key due-diligence should include the firm’s track record in information systems audits, technical competence, audit methodology, and independence safeguards. Audit contracts should clearly define scope, deliverables, timelines and reporting obligations.

  3. Documentation & internal-control evidence
    Since auditors will collect evidence on the operating effectiveness of controls, companies should ensure that their key systems, processes and control activities are documented and tested (or test-ready). This includes change-management, access management, security logging, segregation of duties, incident-management and business-continuity controls. The broader IS audit literature underscores these areas. forvismazars.com+1

  4. Regulatory-reporting & stakeholder communication
    Audit reports may need to be submitted to SPK (or otherwise made available) and might trigger regulatory obligations or disclosures. Firms should therefore anticipate how findings will be addressed (remediation plans, governance committee oversight) and how they will be communicated to shareholders and regulators.

  5. Foreign-investor context
    For foreign investors or multinationals operating in Türkiye, the Guide signals that local entities are subject to increasingly sophisticated IT-audit regimes. Advising on transactions (e.g., acquisitions, joint-ventures, outsourcing) may require assessing whether target firms’ information-systems audit readiness meets SPK expectations.

Role of Legal Advisors

From a legal advisory perspective, the Guide (and the underlying communiqués) offer opportunities for law-firms skilled in corporate-governance, regulatory compliance, audit-contracting and data-protection. Services may include:

  • Drafting or reviewing audit-engagement contracts (scope, deliverables, confidentiality, data protection, legal liability).

  • Advising boards and audit committees on their oversight role in information-systems governance and ensuring proper alignment with business strategy.

  • Reviewing internal control frameworks and liaising with IT governance, risk-management and internal-audit teams to ensure readiness.

  • Assisting with regulatory interface: guiding clients on obligations under SPK communiqués, disclosure requirements, and cross-border implications for data flows/outsourcing.

  • Supporting remediation of audit findings: advising on legal/regulatory implications of control failures, corporate liability and reporting obligations.

Conclusion

For entities subject to SPK-regulated audit oversight, the “Information Systems Independent Audit Introduction Guide” represents a crucial reference point. It underscores that information-systems governance and controls are no longer just an operational matter — they are a critical component of audit and regulatory compliance. Law-firms with expertise in capital-markets regulation, audit contracting and IT-governance can help clients not only respond to audit requirements but also embed effective systems and control frameworks that support corporate value and mitigate risk.

At Cindemir Law Office, we advise domestic and international clients on navigating Türkiye’s regulatory environment, including audit-readiness for information systems under SPK’s regime. Should you require assistance with audit-contract negotiation, readiness assessment or regulatory compliance in this area, we are ready to support.