One of the most important obligations of employers in Turkey is to submit regular and timely tax and social security notifications for their employees to the relevant authorities. These notifications are essential for both the state and workers: they form the backbone of financial order. On one hand they protect workers’ social rights; on the other, they ensure the state collects tax revenues reliably.
Under normal conditions, employers report withholding taxes and Social Security Institution (SGK) premiums together under the “Muhtasar and Premium Service Declaration” (Muhtasar ve Prim Hizmet Beyannamesi). However, in some cases the muhtasar declaration may not be submitted or may be submitted incompletely for various reasons. In that situation the most common employer question is: “How should the premium declaration be submitted if the muhtasar declaration was not filed?”
This issue is particularly important under the 2025 legal framework. Incorrect or incomplete notifications can expose employers to substantial administrative fines and can harm employees’ insurance and retirement rights. Therefore employers must fully understand the process, know the details, and apply procedures carefully to avoid errors.
What Is the Muhtasar Declaration?
First, let’s define the term. The muhtasar declaration is the official document in which employers declare withholding income tax and other taxes deducted from payments made to employees and certain other payments.
Some items reported in the muhtasar declaration include:
- Withholding tax deducted from employees’ wages
- Deductions from professional service payments
- Withholding on rental payments
- Tax deductions from various other entitlements
Beginning as a pilot in 2017 and becoming mandatory nationwide in 2020, the muhtasar declaration was merged with the SGK premium service statement. These two notifications are now submitted together under the Muhtasar and Premium Service Declaration.
What Is the Premium Statement (Monthly Premium and Service Statement)?
The premium statement, formerly called the Monthly Premium and Service Statement, is the document through which employers report employees’ insurance status and earnings subject to premiums to SGK.
Why this document matters:
- Employees’ insured days are recorded.
- Required premium days and earnings for retirement are entered into the system.
- Access to healthcare services is secured.
- Records used for work accident and occupational disease insurance are created.
If an employer does not submit this statement on time:
- Employees’ service records will be incomplete.
- Employees may lose access to healthcare services.
- Retirement calculations may miss contribution days.
- The employer may face significant fines.
How Were the Muhtasar and Premium Declarations Merged?
Previously, employers submitted a muhtasar declaration to the tax office and a separate premium statement to SGK. This dual system caused time loss and inconsistencies for both employers and government agencies.
To address this:
- A pilot was launched in certain provinces in 2017.
- From July 1, 2020, the combined system became mandatory across Turkey.
- Employers now submit both tax and premium information through the Revenue Administration’s (GİB) e-declaration system in a single form.
Under the new arrangement, one electronic declaration contains both tax and social security data and is sent electronically.
What Happens If the Muhtasar Declaration Is Not Submitted?
Failing to submit the muhtasar declaration has consequences under both tax law and social security law.
1- Tax consequences:
- Administrative fines for procedural violations may be applied.
- Penalties for tax loss may be assessed.
- Late payment interest accrues.
2- SGK consequences:
- Employees’ premiums are not recorded.
- Insured days remain incomplete.
- Employees may be unable to access healthcare services.
- There may be loss of retirement rights.
3- Audit risk:
- The likelihood of inspection by the tax office and SGK increases.
- The employer may face more severe sanctions in future audits.
How to Submit the Premium Statement When the Muhtasar Declaration Was Not Filed
Even if the muhtasar declaration was not submitted, an employer can still send the premium statement separately through the SGK system. Doing so protects employees’ rights.
The steps to follow in 2025 are generally:
1- Log into the SGK e-Bildirge V2 system.
Use the employer username and password to access the system.
2- Select the relevant period.
Choose the month for which the premium statement applies.
3- Enter employee information.
- Turkish ID number
- Social security registration number
- Earnings subject to premium
- Number of premium payment days
4- Report missing days.
Include reasons such as medical leave, unpaid leave, or absenteeism where applicable.
5- Approve and submit the statement.
Submitting the premium statement this way preserves employees’ insurance rights even if the muhtasar declaration was not filed.
Points to Watch When Sending the Premium Statement
- Notifications must be made by the 26th of each month.
- If submitted late, administrative fines apply separately for each employee.
- Information must be accurate; errors can lead to fines and correction costs.
- Supporting official documents must be uploaded for missing-day reports.
- Employers should securely store system access credentials and passwords.
Special Cases Where Muhtasar and Premium Declarations Are Filed Separately
Although the combined system is mandatory, separate filings may be possible in limited circumstances:
- Different rules may apply for public institutions.
- Different practices may be used for employees working abroad or in temporary employment relationships.
- If technical issues prevent submission via the GİB system, notifications may be made directly to SGK.
In these situations SGK accepts statements to ensure employees do not lose their rights.
Penalties When Muhtasar and Premium Statements Are Not Submitted
According to the 2025 legal framework, penalties can be severe.
Tax-related penalties:
- Procedural fines (applied per declaration)
- Tax loss penalties (equal to the amount of unpaid tax)
- Late payment interest
SGK-related penalties:
- Administrative fines per employee
- Collection of missing premiums with interest
- Higher penalties for repeated violations
Practical Recommendations for Employers
- Maintain regular payroll monitoring.
- Prepare documents at the start of each month.
- Work with a certified accountant or tax advisor.
- Keep e-Bildirge and GİB credentials secure.
- Notify SGK directly if technical problems occur.
- Prioritize protection of employee rights.
What to Do If the Premium Statement Is Not Submitted
In summary: if the muhtasar declaration is not filed, the premium statement must still be submitted separately through the SGK system. Employers’ obligations remain both in terms of tax and social security.
Remember that:
- Employees’ insurance rights are safeguarded by the premium statement.
- The muhtasar declaration and the premium statement each carry separate responsibilities for tax and SGK purposes.
- Neglect can lead to heavy fines and increased inspections.
Therefore, employers should ensure that both the muhtasar declaration and the premium statement are completed accurately and on time in accordance with the 2025 regulations.