New Regulation by the Social Security Institution (SSI) on Undeclared Employment Inspections

The Social Security Institution has introduced significant changes to the procedures for identifying undeclared employment through Circular No. 2026/22, dated October 19, 2026.

Under the new regulation, rather than automatically classifying individuals named in traffic violation reports as undeclared employees, the existence of an actual employment relationship will be examined. In addition, the rules for determining how employment identified on different dates is reflected in social security coverage periods have been revised.

The use of company-registered vehicles by individuals who are not employees of the company is an important matter to consider in SSI inspections. Particularly for vehicles used in commercial activities, whether the driver is registered as an insured employee of the relevant company may be subject to examination.

However, an important distinction should be noted: Circular No. 2026/22 does not introduce any new provision stating that vehicles classified as "COMMERCIAL" (TİCARİ) in their registration documents may only be driven by company employees, or that vehicles classified as "PRIVATE" (HUSUSİ) may be driven by anyone without restriction. From the SSI's perspective, the determining factor is not the vehicle's registered usage classification, but whether an actual employment relationship exists between the person driving the vehicle and the employer.

Therefore, it is important for companies to maintain appropriate documentation to substantiate the employment status of individuals using company vehicles and the reasons for such vehicle use, when necessary.

Under the previous practice, social security determinations based on traffic violation reports could directly result in retrospective reporting and social security premium obligations for employers.

Another significant amendment introduced by the Circular concerns the calculation of employment periods identified through reports prepared by public authorities.

Under the new procedure, where an individual is found to have worked at the same workplace on different dates, the entire period between those dates will no longer automatically be considered a continuous period of employment. Instead, one day of social security coverage will be credited for each separate day on which actual employment has been established.

The date of the first determination will be considered the employment commencement date. If further employment is identified in subsequent months, the number of insured service days will be determined accordingly. However, if no employment is identified during a particular month and employment is subsequently identified again in a later month, a new employment registration may be required.

Although the new regulation introduces a more detailed examination process for employers in cases involving undeclared employment, it does not eliminate their obligations to register employees for social security purposes and submit the required notifications.

In this context, companies should review the employment relationships of individuals using their vehicles, prepare the necessary documentation for personnel assignments between group companies, and maintain accurate records of actual employment activities.

In particular, where vehicles belonging to group companies are used by employees of other group entities, or where company vehicles are driven by individuals who are not employees of the company, the legal basis and actual circumstances of such vehicle use should be clearly documented and justifiable in the event of an SSI inspection.

You can access further details on this matter in the Amendment to Circular No. 2015/25. (In Turkish)