Revised SHT-6AF: Key Changes to the Financial Oversight of Commercial Air Transport Operators

The Directorate General of Civil Aviation (“SHGM”) published the revised Instruction on the Financial Audit of Commercial Air Transport Operators (“SHT-6AF” or the “Instruction”) on 16 October 2026, repealing the previous Instruction dated 4 August 2015.

While preserving the overall framework for financial oversight, the revised Instruction introduces material changes to financial reporting, assessment criteria, notification procedures and administrative measures. It also simplifies periodic reporting for air taxi operators and more clearly allocates responsibility for the timely, accurate and complete submission of financial information by airline operators.

The timing is notable. The revised Instruction enters into force during a period of increased financial pressure on airlines, including higher fuel and maintenance costs, aircraft and engine availability constraints, and geopolitical and airspace disruption. There is no published indication that SHGM introduced the changes specifically in response to expected 2026 airline losses. The revised framework nevertheless places less emphasis on predetermined financial and operational triggers and greater emphasis on the operator’s overall financial position, liquidity and ability to maintain operations.

A New Approach to Financial Oversight

Under the previous framework, operators’ financial information packages were assessed using generally accepted financial analysis ratios and aviation industry averages, with the results reflected in a financial performance scorecard. The revised Instruction no longer provides for either the scorecard or the use of industry averages.

Instead, airline operators’ financial statements are assessed by reference to financial structure, profitability, liquidity, equity adequacy and activity ratios. The assessment also takes into account trade and non-trade receivables and payables involving related parties and uses generally accepted financial analysis ratios together with the operator’s historical Financial Information Package data.

The previous standalone assessment criteria of “recoverability of receivables” and “overdue trade payables” are no longer separately identified, while “financial structure” and “activity ratios” have been added.

Equity Adequacy

The previous Instruction contained detailed rules for determining whether the paid-in capital required under SHY-6A remained within an operator’s year-end equity, including calculations based on the Central Bank of the Republic of Türkiye’s foreign exchange selling rates. It also prescribed a separate US dollar calculation for operators that had lost paid-in capital.

These provisions have been removed.

The revised Instruction instead provides that the financial position of airline and air taxi operators is to be assessed against the equity adequacy requirements under SHY-6A.

This does not remove the underlying equity adequacy requirement. Rather, SHT-6AF no longer contains a separate calculation methodology and refers directly to the requirements applicable under SHY-6A.

Financial Reporting Remains Largely Unchanged

The new SHT-6AF largely preserves the existing financial reporting framework for airline operators. Airlines remain required to submit a Financial Information Set to SHGM on a quarterly basis, with quarterly submissions due within eight weeks following the end of the relevant accounting period and the year-end submission due by the end of April of the following year. The Financial Information Set continues to be prepared in accordance with Turkish Financial Reporting Standards (TFRS). Airlines must also continue to submit an annual independent audit report, including its notes, prepared in accordance with the Turkish Standards on Auditing (TDS) by the end of April.

Simplified Reporting for Air Taxi Operators

The revised Instruction reduces the periodic reporting requirements applicable to air taxi operators. The previous requirements to submit statutory financial statements every six months and to provide provisional tax returns and financial statements for the first six months of the year have been removed. Air taxi operators must instead submit their year-end tax return and financial statements to SHGM by the end of April of the following year. The amendment therefore reduces the frequency of periodic reporting without removing the year-end reporting requirement or SHGM’s financial oversight.

Notification Requirements and Material Events

The revised Instruction changes both the form and scope of notifications to SHGM. Significant events under Article 8 must now be notified through a written submission signed by the responsible personnel, rather than being disclosed with their reasons in the notes to the relevant Financial Information Set.

The revised notification framework covers:

• collection problems relating to trade or other receivables where they may result in cash-flow difficulties;

• the acquisition, establishment or disposal of subsidiaries or associates in Türkiye or abroad;

• the sale of aircraft owned by the operator; and

• other developments affecting income or expenditure that may result in cash-flow difficulties.

  
  

Capital, Ownership and Management Changes

The revised Instruction also changes the notification period for changes in capital, shareholding and management structure.

For capital increases and changes in shareholders, the board of directors or the board of partners, the 15-day period for submitting official information and documents to SHGM previously ran from the date of the relevant decision. Under the revised Instruction, the period runs following publication of the relevant decision in the Trade Registry Gazette. The amendment therefore ties the notification period to a publicly ascertainable publication date rather than the date of the underlying corporate decision.

Management Responsibility

The revised SHT-6AF expressly identifies the management personnel responsible for financial affairs, together with the general manager, as responsible for the timely, accurate and complete submission of information in the Financial Information Set.

The amendment clarifies the management function responsible for compliance and reinforces the need for consistency between regulatory submissions, TFRS financial statements and the annual independent audit report.

Payment Obligations and Operational Continuity

The revised Instruction continues to monitor an operator’s obligations to critical aviation creditors, including:

• employees;

• EUROCONTROL;

• aircraft lessors;

• maintenance and fuel providers;

• ground-handling companies;

• airport operators;

• public authorities; and

• other suppliers.

  
  

The current wording focuses on payment delays that would prevent the continuation of operations. The regulatory focus is therefore not simply on the existence of an overdue liability, but on whether payment difficulties have developed to a level capable of affecting operational continuity. This remains separate from contractual default. A payment delay may constitute a default under a lease, financing or supply agreement even where it has not reached the level contemplated by SHT-6AF.

Reduced Prescriptive Measures

The previous Instruction expressly identified a number of measures that could be taken in cases of financial inadequacy. These included the full or partial rejection of applications to add aircraft to the fleet, introduce new routes, expand the scope of an operating licence or enter into aircraft leasing arrangements.

The previous framework also contemplated additional letters of guarantee and, in specified circumstances, the full or partial suspension of flights. These detailed measures have not been retained in the revised Instruction. Under the revised Article 10, where SHGM identifies an adverse financial condition, the operator may instead be warned and required to take measures to correct its financial position.

Administrative Fines for Reporting Breaches

The revised Instruction refers to administrative fines under SHY-İPC where the Financial Information Package or independent audit report is not submitted within the prescribed period, or where inaccurate, misleading or incomplete information affecting the operator’s financial performance is provided.

Taken together, the amendments reflect a shift from a more prescriptive framework based on specific triggers and predetermined measures towards a broader assessment of each operator’s financial position and operational continuity.