Important Announcement from SSI to Employers per Circular No. 2024/14

This informative note about Circular No. 2024/14 issued by the Social Security Institution (SSI) outlines key procedures and principles for employers regarding the late submission of monthly premium and service declarations (APHB) and consolidated withholding and premium service declarations (MUHSGK).

Key highlights of the circular include:

Documents Submitted After the Legal Deadline

The circular references relevant provisions of the Social Insurance Transactions Regulation and introduces important changes regarding the evaluation of documents submitted after their legal deadlines.

1. Three-Month Period:

Monthly premium and service declarations submitted within three months of the legal deadline may be processed without further examination if specific conditions are met. It is required that the employee registration declaration of insured employees listed in these documents were submitted within the legal timeframe.

2. Review Process:

Documents submitted after the three-month period will be subject to review by institutional inspectors. For correction-related documents, if the insured employees' premium payment days and earnings are unchanged, administrative fines will not apply.

3. Points for SSI Units:

SSI units must adhere to the following when processing documents and declarations:

Ensuring that document processing is conducted via the “Accrual-Input-Accrual Transactions-Registry Entry” screen in the Employer Intra system.

Avoid delaying document approval processes until the last day of the submission period. In cases where delays occur, promptly notify employers and complete document approval processes without further delay.

4. New Provisions for Accrual and Payment Delays:

Despite the issues outlined above, specific provisions have been made for the following scenarios:

• Unsubmitted Documents Due to Outstanding Debts:

If monthly premium and service declarations or consolidated withholding and premium service declarations are not submitted on time due to debts arising from processing the declarations on the last day, these documents will be considered submitted within the legal timeframe if submitted with a (B) accrual code.

• Unsubmitted Documents Due to Payment Delays:

Similarly, if declarations are not submitted on time because payments for previous periods were not transferred to the account by 23:59 on the last day, the same rule applies.

In these cases, the documents are submitted within five working days following the deadline with a (B) accrual code, will be considered submitted within the legal timeframe, and no administrative fine will be imposed pursuant to Article 102 of Law No. 5510.

5. Conclusion and Recommendations:

Circular No. 2024/14 introduces significant provisions to help employers fulfill their legal obligations on time and avoid potential penalties. Under this circular, employers are granted a crucial five-business-day extension for documents or declarations that could not be submitted within the legal timeframe due to accrued debts from prior periods or payments processed on the last day of the submission period but not credited to the account by 23:59. It is of utmost importance for employers to ensure the timely submission of documents within the legal deadlines and to properly manage their responsibilities during correction processes. Additionally, SSI's relevant units must efficiently manage these processes and provide timely notifications to employers.

This circular serves as a guide for employers and subcontractors, offering an important tool to streamline procedures and ensure compliance with regulations.

You can access the relevant Circular here. (In Turkish)

Should you have any queries or need further details, please contact your customer representative.