
IV Macro Policy & Sovereign Debt·Analysis·Türkiye and Its Neighbourhood
Ankara keeps currency losses off balance sheets as the FX gap widens
Two communiqués on 10 October: companies may keep FX losses out of capital tests until 2028, and four power distributors' advances slip to end-2027. The loss is deferred, not written off. The constraint is a corporate FX gap of $205.8 billion in June.
Türkiye & Neighbourhood Desk · 11 October 2026 · 8 min read · 16 sources
Why it matters
The noise: the change to Article 376 of the Turkish Commercial Code in the 10 October Official Gazette reads like a technical date fix. The signal: Ankara has hidden FX-indebted companies' currency losses for yet another year, and did so roughly 12 months before the deadline. According to the CBRT, non-financial companies' net FX short position rose to $205.8 billion in June. Their short-term FX surplus shrank from $9.8 billion to $6.6 billion in a month. The lira has lost about 17.8% in 12 months. The deferral is a bet that the currency holds, and CBRT reserves are the collateral.
Implications
- Under the Trade Ministry's 10 October communiqué, companies may exclude FX losses on unpaid foreign-currency debt from capital-loss and insolvency tests until 1 January 2028. The previous cut-off was 1 January 2027.
- CBRT data show non-financial companies' net FX short position rising by $2.3 billion in June to $205.8 billion. Their short-term net FX surplus fell by $3.2 billion to $6.6 billion.
- The same day EPDK, the energy regulator, deferred advance payments by the Akedaş, Dicle, Fırat and Toroslar distributors interest-free until 31 December 2027. A year earlier the earthquake-related deferral had been extended to end-2026.
Noise
The Article 376 change is a technical date fix
Signal
Companies' short-term FX buffer is thinning fast
The noise is in the date, the signal in the timing
Official Gazette No. 33396 of 10 October 2026 carried a short communiqué from the Trade Ministry. According to Alomaliye, it changed the date in the provisional article of a 2018 communiqué on Article 376 of the Turkish Commercial Code from 1/1/2027 to 1/1/2028. The news flow treated it as a one-line date change. That is the noise. The amendment looks technical, but the assumption behind it is not.
Article 376 requires the board of a company that has lost half or two-thirds of its capital to convene the general assembly and restore the capital. An insolvent company must notify the court. The exemption lets companies ignore the full FX loss on unpaid foreign-currency debt in this test. Half of the rent, depreciation and staff costs accrued in 2020–2021 can also be left out. Use of the exemption is optional and disclosed in the footnotes.
The extension came 12 months early
According to a 10 December 2025 report in Karar, the previous extension moved the cut-off to 1 January 2027. That extension was made on 10 December 2025. This time the ministry acted roughly 12 months before the new deadline. The sequence suggests Ankara expects currency pressure on balance sheets to persist throughout 2027.
A second deferral came the same day. Bloomberg HT reports that EPDK deferred balancing-market advance payments by the Akedaş, Dicle, Fırat and Toroslar distributors, and by the incumbent suppliers in those regions, interest-free until 31 December 2027. According to YatırımX, the same decision was taken on 28 October 2025 to run until end-2026, citing the earthquakes of 6 February 2023. Some 44 months have passed since the earthquakes; the deferral is turning into a permanent source of funding.
The fix for the fund crisis follows the same logic. A bill submitted to parliament on 9 October would revalue principal in 131 liquidating funds by the average of CPI and PPI. The government says no public money will be used. What the three cases share is that the question of whose balance sheet takes the loss is being moved from today to tomorrow.
The constraint is the FX gap
Corporate balance sheets explain why the deferral has come now. CBRT data cited by Bloomberg HT show non-financial companies' net FX short position rising by $2.3 billion in June to $205.8 billion. The main driver was a $3.6 billion increase in derivative liabilities. In the same month, FX deposits at domestic banks fell by $1.6 billion.
The more sensitive gauge is the short end. Data cited by Uzmanpara show companies' short-term net FX position still in surplus by $6.6 billion in June. But that surplus shrank by $3.2 billion in a single month. Short-term FX assets stand at $150.1 billion against liabilities of $143.5 billion. If the lira weakens while this buffer thins, companies will run out of FX assets to cover the foreign-currency debt they must repay within a year.
The currency side is clear. Trading Economics put USD/TRY at 49.27 on 9 October, and the lira has lost about 17.8% over the past 12 months. Without the exemption, the translation loss on unpaid FX debt from that depreciation would be deducted from equity. There is no official data on how many companies use the exemption, which makes the size of the constraint hard to measure.
Where the hidden loss surfaces
The exemption protects the balance sheet, not cash flow. Data cited on 14 August by CHP MP Ömer Fethi Gürer show 3,529 concordat rulings in the first seven months of 2026, of which 1,146 were rejections and 171 bankruptcies. The figures could not be verified against an official database. Ekonomi Gazetesi, drawing on Konkordatotakip data, reported that bankruptcy rulings reached 141 in the first eight months of 2025, more than in all of 2024.
Capital markets show traces too. According to Türkiye Today, Tera Yatırım Bankası failed to repay at maturity a roughly 6.05 billion lira commercial paper issued on 6 April with a 182-day tenor. It is a concrete case of a loss leaving the balance-sheet footnotes and landing on the payment calendar in the corporate debt market.
Reserves are the collateral for the deferral
This picture ties the MPC's hands. Bloomberg HT reports that Goldman Sachs, in a 7 October note, said it does not expect a cut on 22 October. The bank stressed that reserve losses have accelerated since the effective 300-basis-point cut. CBRT data for 8 October show net reserves excluding swaps down to $37.9 billion. In a system that defers FX losses off the balance sheet, a jump in the lira means the deferred loss is recognised in one go. That strengthens the CBRT's inclination to hold the currency steady with reserves.
Domestic benchmark yields show the market does not expect rapid easing either. Bloomberg HT's benchmark screen on 11 October showed the 2-year yield at 39.59% and the 10-year at 35.52%. The screen is not updated at weekends, so we treat these as 9 October closes. The 2-year yield sits above the 37% policy rate.
Our thesis is that the deferrals are not a crisis but a maturity extension tied to currency stability. The loss does not disappear; only its recognition is postponed. The thesis would be refuted if CBRT data for July and August showed companies' net FX short position falling below $195 billion and the short-term surplus recovering above $9 billion.
Probabilities
Scenarios
| Scenario | Probability | Trigger | Market impact |
|---|---|---|---|
| H1A quiet maturity extension | 55% | USD/TRY rises gradually and stays below 50.50, the CBRT holds rates in October, and reserves move sideways. | The exemption keeps the loss on the balance sheet, corporate failures stay high but not systemic, and the exemption is extended again at end-2027. |
| H2The deferred loss surfaces | 30% | USD/TRY breaks above 50.50, the short-term FX surplus turns into a deficit, and a large company or commercial-paper issuer misses a payment. | The FX loss hidden by the exemption turns into a cash crisis, concordat and bankruptcy rulings spike, and the CBRT is forced to tighten or take a macroprudential step. |
| H3Currency stability becomes durable | 15% | Brent eases, reserves recover, and companies' net FX short position falls below $195 billion. | Companies start covering FX losses with capital increases, the exemption lapses at end-2027 without renewal, and the CBRT finds room to cut. |
Module A
Constraints Matrix
STRUCTURAL AVG 4.5 · TACTICAL AVG 2.7Structural constraints dominate: the outcome is set more by these limits than by the actors' preferences.
Hard structural constraintspersistent · beyond the actors' will
The corporate FX gap · Türkiye
5/5Non-financial companies' net FX short position stood at $205.8 billion in June; it rose by $2.3 billion in the month, driven by a $3.6 billion increase in derivative liabilities.
Net reserves excluding swaps · Türkiye
5/5$37.9 billion in CBRT data for the week of 2 October; the cost of holding the currency steady is drawn from this buffer.
The short-term FX buffer · Türkiye
4/5The short-term net FX surplus fell by $3.2 billion in June to $6.6 billion; assets of $150.1 billion against liabilities of $143.5 billion.
Currency depreciation
4/5The lira has lost about 17.8% against the dollar over the past 12 months; USD/TRY stood at 49.27 on 9 October.
Tactical frictiontemporary · eases over time
Loss of transparency months
3/5Use of the exemption is optional and disclosed in footnotes; there is no official data on how many companies use it, which makes credit risk harder to measure.
Concordat and bankruptcy flow months
3/5Of 3,529 concordat rulings in the first seven months of 2026, 1,146 were rejections and 171 bankruptcies; the figure could not be verified against an official database.
Deferrals becoming permanent months
2/5EPDK's earthquake-related advance deferral now runs to end-2027; principal in liquidating funds will be revalued by the average of CPI and PPI.
Module B
Signal vs Noise
SIGNAL 67% · NOISE 33%
- NOISE
The Article 376 change is a technical date fix
The communiqué only changes 1/1/2027 to 1/1/2028, yet the extension came about 12 months before the cut-off; the previous one was made in December 2025.
Alomaliye — Deadline extended for the capital-loss calculation
- SIGNAL
Companies' short-term FX buffer is thinning fast
The short-term net FX surplus fell by $3.2 billion in a single month to $6.6 billion in June; the overall net short position is $205.8 billion.
Data: USD/TRY ›Uzmanpara — Non-financial companies' net FX gap widened in June
- SIGNAL
Deferral is spreading across the system, not one sector
The same day EPDK deferred four distributors' advance payments interest-free until 31 December 2027; a year earlier the same deferral had been extended to end-2026.
Bloomberg HT — Advance payments of four power distributors deferred
- SIGNAL
Losses have started to hit the payment calendar
Tera Yatırım Bankası failed to repay at maturity a roughly 6.05 billion lira commercial paper issued on 6 April with a 182-day tenor.
- NOISE
A flat lira shows corporate balance sheets are sound
USD/TRY moved 0.01% on the day to 49.27 on 9 October, but the lira has lost about 17.8% in 12 months and the calm is bought with reserves.
- SIGNAL
Reserve losses are shrinking the CBRT's room to cut
Goldman Sachs wrote in a 7 October note that it does not expect a cut on 22 October and that reserve losses accelerated after the effective 300-basis-point cut.
Bloomberg HT — Goldman says October is too early for a CBRT rate cut
Module C
Asset-Class and Positioning Implications
| Asset class | Exposure | Transmission channel | H1 | H2 | H3 | Expected | Conviction | Horizon | What to watch |
|---|---|---|---|---|---|---|---|---|---|
| FX | USD/TRY path | Deferred FX losses make a currency jump costly for the system; the CBRT keeps holding the lira with reserves | 0 | −− | + | −0.45 | ●●● | 0–3 months | Weekly net reserves excluding swaps and the 50.50 threshold on USD/TRY |
| Credit | Türkiye 5-year CDS | If hidden corporate losses surface, they feed into the sovereign risk premium | 0 | −− | ++ | −0.30 | ●●● | 3–12 months | CDS thresholds at 270 and 230 basis points |
| Credit | Domestic corporate bonds and commercial paper | Payment failures and weaker transparency push up the corporate borrowing premium | − | −− | + | −1.00 | ●●● | 3–12 months | Commercial-paper issuance yields over Treasury bills |
| Sovereign debt | Lira government bonds, front end | Reserve pressure narrows room to cut; if currency stability holds, cuts get priced | − | −− | ++ | −0.85 | ●●● | 0–3 months | The domestic 2-year benchmark yield over the 37% policy rate |
| Equities | Banks | Rising non-performing loans and hidden losses on corporate balance sheets weaken credit quality | − | −− | ++ | −0.85 | ●●● | 3–12 months | BDDK monthly non-performing loan ratio |
Second-order effects
And then what?
Starting point
Under the 10 October communiqué, companies may keep FX losses on unpaid foreign-currency debt out of the capital test until 1 January 2028. Meanwhile their net FX short position stands at $205.8 billion and their short-term FX surplus at $6.6 billion.
- 1
Corporate FX positionwithin weeks
The FX loss hidden from the balance sheet grows on the cash side as the lira weakens. The short-term surplus erodes, and companies turn to FX loans from domestic banks or derivative hedges to roll their foreign-currency debt.
Watch: The short-term net position in the CBRT's monthly data on companies' FX assets and liabilities
- 2
Reserves and the lirawithin weeks
Part of that FX demand lands on CBRT reserves through the derivative and spot markets. To stop a currency jump forcing recognition of the deferred loss in one go, the CBRT keeps spending reserves and postpones cuts.
Watch: Weekly net reserves excluding swaps and the 22 October MPC decision
- 3
Credit qualitywithin months
As long as rates stay high, payment failures rise among cash-poor companies. Concordat rejections and bankruptcy rulings increase, banks' non-performing loans grow and the premium on corporate paper widens.
Watch: Monthly concordat and bankruptcy ruling counts and the BDDK non-performing loan ratio
What breaks the chain
The chain breaks if the lira holds steady in real terms and the short-term FX surplus climbs back above $9 billion. It also breaks if a fall in Brent eases the external balance enough for the CBRT to cut without spending reserves.
Triggers
Thresholds to watch
| Indicator | Threshold | Today | What it means |
|---|---|---|---|
| USD/TRY | > 50.50 | 49.17 | If USD/TRY moves from 49.27 on 9 October above 50.50, FX losses on unpaid debt grow fast and the gap the exemption hides hits the payment calendar; H2 moves to the fore. |
| Türkiye 5-year CDS | > 270 bp | 248 | CDS above 270, from 248.43 on 8 October, would mean foreign investors have started adding the corporate sector's hidden losses to sovereign risk. |
| Türkiye 5-year CDS | < 230 bp | 248 | CDS below 230 marks the zone where currency stability becomes durable and the exemption could lapse at end-2027 without renewal; H3 strengthens. |
Sources
- Alomaliye — Deadline extended for the capital-loss calculation
- Bloomberg HT — Relief for companies with capital losses or insolvency extended
- Karar — Companies' FX loss relief extended to 1 January 2027
- Bloomberg HT — Advance payments of four power distributors deferred
- YatırımX — EPDK decision made official: Dicle, Fırat, Toroslar and Akedaş advances deferred
- Bloomberg HT — Real-sector net FX gap reached $206 billion in June
- Uzmanpara — Non-financial companies' net FX gap widened in June
- Trading Economics — Turkish lira
- 24 Saat — Concordat warning from CHP's Gürer
- Ekonomi Gazetesi — Concordats overtook 2024 in eight months
- Türkiye Today — Tera's bank fails to pay $123M bond after fund defaults roil Turkish market
- Bloomberg HT — Goldman says October is too early for a CBRT rate cut
- Dünya — CBRT data: reserves fell by about $4 billion
- Bloomberg HT — Bond yields
- Bigpara (AA) — Bill on the liquidation of investment funds submitted to parliament
- Investing.com — Turkey CDS 5 Years USD historical data
Sourcing and verification rules: methodology · Report an error: contact
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