SSI Circular on Meal Allowance Exemption Published

The Circular No. 2026/12 dated May 7, 2026 published by the Social Security Institution ("SSI"), provides significant explanations regarding the implementation of the meal allowance exemption. The Circular explains in detail the circumstances under which meal benefits provided by employers to employees may be included in earnings subject to social security premiums.

As is known, certain amendments were introduced to various laws through Law No. 7577 on the Amendment of Certain Laws, published in the Official Gazette dated April 7, 2026 and numbered 33227. In line with these amendments, the following provision was added to subparagraph (b) of the first paragraph of Article 80 of the Social Insurance and General Health Insurance Law No. 5510, dated May 31, 2006: "9) In cases where meals are not provided by the employer at the workplace or its appurtenances, the portion of the daily meal allowance corresponding to the days worked, up to TRY 300, shall not be subject to earnings taken as the basis for premium calculation. The amount specified in subparagraph (9) shall be applied by increasing it each year by the revaluation rate determined pursuant to paragraph (B) of repeated Article 298 of Law No. 213 for the previous year. Fractions not exceeding 5% of the amount calculated in this manner shall not be taken into account." Accordingly, it has been regulated that, where meals are not provided by the employer at the workplace or its appurtenances, the portion of the daily meal allowance corresponding to the days worked, up to TRY 300, shall not be subject to earnings taken as the basis for premium calculation. Due to this amendment, a Circular clarifying the principles of implementation was published by the SSI on May 7, 2026.

You can access detailed information regarding Law No. 7577 on Amendments to Certain Laws here.

As stated above and also specifically emphasized in the Circular, in cases where meals are not provided by the employer at the workplace or its appurtenances, the daily amount of meal allowance corresponding to the days worked that will be exempt from earnings subject to social security premiums has been determined as TRY 300, effective as of April 17, 2026. Accordingly, the amount to be included in earnings subject to social security premiums from payments made under the name of meal allowance shall be calculated as follows:

• Daily Exemption Amount = TRY 300
• Number of Days Actually Worked During the Month x TRY 300 (Daily Exemption Amount) = Monthly Exemption Amount
• Monthly Meal Allowance Paid – Monthly Exemption Amount = Meal Allowance to be Included in Earnings Subject to Social Security Premiums

On the other hand, the daily amount of meal allowance to be exempt from earnings subject to social security premiums, which will be applied as TRY 300 as of April 17, 2026, shall be increased in the following years by the revaluation rate determined each year for the previous year pursuant to paragraph (B) of repeated Article 298 of the Tax Procedure Law No. 213.

In the Circular, matters relating to different practices are explained in detail, and the relevant practices and current situation are set out below:

1. Application Where Meal Service Is Provided to Insured Employees at the Workplace or Its Appurtenances

Where employers provide meal service to insured employees at the workplace or its appurtenances through their own means, or where meals purchased by employers from persons providing ready-made meal services are provided to insured employees at the workplace or its appurtenances, the entire meal cost shall be exempt from earnings subject to social security premium, without being subject to any monetary limit.

Any contribution made by the insured employee to the meal cost under names such as meal fee or similar shall have no significance for the purposes of applying the exemption, other than affecting the cost of the meal for the employer.

2. Application Where Meal Service Is Not Provided to Employees at the Workplace or Its Appurtenances

Where meal service is procured from businesses providing meal services, the portion of the payments made to such businesses corresponding to a daily meal allowance of up to TRY 300 for each employee for the days worked shall not be included in the earnings subject to premium.

Where meal service is provided through meal coupons, meal cards, meal vouchers and similar instruments, the portion corresponding to a daily meal allowance of up to TRY 300 for each employee for the days worked shall not be included in the earnings subject to premium.

Where meal service is provided in cash, the portion corresponding to a daily meal allowance of up to TRY 300 for each employee for the days worked shall not be included in the earnings subject to premium.

3. Other Specific Matters Regarding Meal Allowance

3.1.

As explained in the Circular, meal service, in its broadest sense, is a benefit provided to meet the employee's nutritional needs and thereby enable the employee to work efficiently. Therefore, where the employee purchases and consumes food items to meet their nutritional needs by using cash provided to them for meal service or through meal coupons, meal cards, meal vouchers and similar instruments, the portion of such payment corresponding to a daily meal allowance of up to TRY 300 per employee for the days worked shall not be included in the earnings subject to social security premium.

3.2.

Pursuant to the provision under Article 12 of the Minimum Wage Regulation, titled "Employer's Liability", which states that "No deduction may be made from the minimum wage on account of social benefits provided to employees by employers," the meal allowance must be provided in addition to the minimum wage. Accordingly, the meal allowance amount shall not be included in the gross minimum wage, namely the lower limit of earnings subject to premium.

3.3.

Where meal service is provided to some employees working at the same workplace at the workplace or its appurtenances, and to other employees through the other methods explained in the relevant Circular, the entire meal cost for the employees who are provided with meal service at the workplace or its appurtenances shall be exempt from earnings subject to social security premium, without being subject to any monetary limit. For employees who are provided with meal service through other methods, the portion corresponding to a daily meal allowance of up to TRY 300 for the days worked shall not be included in the earnings subject to premium. 3.4.

Where an employee benefits from meal service provided at the workplace or its appurtenances on all days actually worked, and is also provided with meal service through the other methods explained in the relevant Circular, the entire meal cost in respect of the meal service provided at the workplace or its appurtenances shall be exempt from earnings subject to social security premium. However, in respect of meal service provided through other methods, the entire daily meal allowance for the days worked shall be included in the earnings subject to premium.

For example, assuming that employee A actually works for 22 days in May 2026, benefits from the meal service provided at the workplace on all 22 days actually worked, and is also paid a meal allowance in cash for the days actually worked, the entire meal cost in respect of the meal service provided at the workplace shall be exempt from earnings subject to social security premium. However, since the employee benefited from meal service at the workplace for 22 days, the entire amount of the meal allowance additionally paid in cash for the days actually worked must be included in the earnings subject to premium.

3.5.

Where an employee benefits from meal service provided at the workplace or its appurtenances on some of the days actually worked, and benefits from meal service through the other methods explained in the relevant Circular on the remaining days when they do not benefit from the meal service provided at the workplace or its appurtenances, the entire meal cost in respect of the meal service provided at the workplace or its appurtenances shall be exempt from earnings subject to social security premium. In respect of meal service provided through other methods, the portion of the daily meal allowance for the days worked that does not exceed TRY 300 shall not be included in the earnings subject to premium.

For example, assuming that insured employee A actually works for 22 days in May 2026, benefits from the meal service provided at the workplace for 12 days, and is paid TRY 4,000 in cash as meal allowance for 10 days, the entire meal service benefited from at the workplace for 12 days shall be exempt from earnings subject to social security premium. In respect of the meal service provided in cash for 10 days, the portion of the daily meal allowance for the days worked up to TRY 300 shall not be included in the earnings subject to premium. In this case, the amount to be included in the earnings subject to premium from the payment made in cash under the name of meal allowance for 10 days shall be as follows:

• Daily Exemption Amount: TRY 300
• Total Exemption Amount: 10 days x TRY 300 = TRY 3,000
• Meal Allowance to Be Included in Earnings Subject to Premium: TRY 4,000 – TRY 3,000 = TRY 1,000

3.6.

If any sham arrangements are identified in relation to any payments made to insured employees or to third parties on behalf of insured employees under the name of meal service, the Institution's premium loss shall be collected from employers together with late payment interest and penalty pursuant to Article 89 of Law No. 5510.

3.7.

The matters explained in this Circular shall apply to transactions to be carried out as of April 17, 2026.

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