Ministry of Transport and Infrastructure Authorization Documents Guide: Capacity, Capital and Current Rules

Legal compliance is the most basic condition of financial and legal risk management for enterprises operating commercially or privately in the road transport sector. The conditions of minimum capacity, number of vehicles, operating capital, and manager (ÜDY/ODY) employment of the authorization documents issued under the Road Transport Regulation (KTY) have been significantly updated with the regulation amendments and circulars published in recent years.

In this guide, we will examine the most current legal conditions in detail for all authorization document types in alphabetical order, including the Official Gazette regulations dated May 16, 2024, and June 19, 2024.

⚠️ Important Legal Rule
📌 Capital Requirement vs. YDO Distinction (Legal Reminder): The minimum operating capital requirements determined in the Road Transport Regulation are fixed and remain the same until the legislation article is officially changed (they do not automatically increase with the Revaluation Rate every year). However, the Authorization Document Fees (Harçlar) and Administrative Fines to be paid to the Ministry are applied by being increased according to the Revaluation Rate (YDO) every year.

📢 The Most Critical Recent Reforms Affecting the Transportation Sector

The current reforms that companies operating in the sector or applying for a new document must know are as follows:

  • UETS Obligation (Strict Inspection is Active): It has been made mandatory for authorization document holders to become members of the National Electronic Notification System (UETS) and the final compliance date has been applied as January 1, 2025 (end of December 31, 2024). Since this period has expired, document holders whose UETS account is not active are not allowed to perform any operational transactions such as adding a vehicle, dropping a vehicle, or renewing a document via U-Net or e-Government, and the system directly blocks them.
  • Age Limit Flexibilities and Limits:
    • Upper Limit: Due to the driver shortage, the upper age limit for driving commercial vehicles has been extended from 66 to age 66 (provided that they have not started the age of 66) with temporary circulars published. In accordance with the "gün alma" (taking a day from the new age) principle in Turkish law, drivers are considered to have stepped into their 69th age on the day they turn 68, and they can no longer drive commercially.
    • Lower Limit: The lower age limit required for drivers who will drive large buses has been reduced from 26 to 24 in harmonization with the Highway Traffic Law.
  • B2 and D2 Automobile Registration (VIP Driving Conditions): In order to register an automobile to B2 and D2 passenger and tourism documents, it is a prerequisite to have at least 8 self-owned buses in the fleet. The automobiles to be added must be self-owned, maximum 8 years old, and have an engine cylinder volume of 1,900 cc and above (suitable for 2.0L VIP standards such as Vito, Transporter, etc. on the market).
  • TİO Minimum Capital Update (June 19, 2024): The minimum capital requirement for the TİO document, which regulates integrated transport affairs organization, has been increased to 1,000,000 TL.
  • C2 Document Completely Removed: As of January 14, 2023, the C2 document in international commercial freight transport was removed, and all existing documents were directly converted to the L2 Authorization Document.
  • Scope of B3 and D3 Expanded: The scope of B3 and D3 documents engaged in private transportation has been expanded to include the transportation of patients receiving treatment in their own dialysis centers and disabled individuals receiving education in their own special education/rehabilitation centers and their parents/guardians, in addition to their own personnel.
  • BTK Prerequisite in P and M Courier/Cargo Documents: The old number of vehicles and capital limits in KTY for Distribution (P1, P2) and Cargo (M1, M2) authorization documents have been removed, and applications have been completely tied to the standards of the BTK's Authorization Regulation on the Postal Sector.

🚍 Passenger Transportation (A, B, D Type Authorization Documents)

Type A (Passenger Transportation by Automobile)

  • A1 Authorization Document (Domestic Scheduled/Unscheduled): Issued to those who will perform commercial passenger transportation domestically by automobile.
    • Capacity: At least 4 self-owned automobiles.
    • Capital: Minimum 20,000 TL capital.
    • Special Condition: The document fee is applied as 12 times for initial applications that will provide service outside the public contract.
  • A2 Authorization Document (International Unscheduled): Issued to those who will perform international unscheduled passenger transportation by automobile.
    • Capacity: At least 5 self-owned automobiles.
    • Capital: Minimum 40,000 TL capital.

Type B (International and Domestic Passenger Transportation by Bus)

  • B1 Authorization Document (Scheduled Commercial): Scheduled international and domestic commercial passenger transportation.
    • Capacity: At least 150 seat capacity with self-owned buses.
    • Capital: Minimum 100,000 TL capital.
  • B2 Authorization Document (Unscheduled Commercial): Unscheduled (tourism, group) international and domestic passenger transportation.
    • Capacity: At least 90 seat capacity with self-owned buses.
    • Capital: Minimum 50,000 TL capital.
  • B3 Authorization Document (Private): Issued to institutions that will transport their own personnel, dialysis patients, and rehabilitation students.
    • Capacity: At least 1 self-owned bus.
    • Capital: No capital requirement (it is a private/non-commercial document).

Type D (Domestic Passenger Transportation by Bus)

  • D1 Authorization Document (Intercity Scheduled): Domestic intercity scheduled passenger transportation.
    • Capacity: At least 150 seat capacity with self-owned buses.
    • Capital: Minimum 60,000 TL capital.
  • D2 Authorization Document (Domestic Unscheduled): Domestic tourism and unscheduled group passenger transportation.
    • Capacity: At least 75 seat capacity with self-owned buses.
    • Capital: Minimum 30,000 TL capital. (No minimum capacity is required for those who will only transport disabled/dialysis patients, 1 vehicle is sufficient and the document fee is 97% discounted).
  • D3 Authorization Document (Private Domestic): Issued to institutions that will transport their own personnel, dialysis patients, and rehabilitation students domestically.
    • Capacity: At least 1 self-owned bus.
    • Capital: No capital requirement.
  • D4 Authorization Document (Intra-city and Intercity under 100 km): Scheduled and unscheduled passenger transportation within the city or at distances up to 100 km.
    • Capacity: At least 1 self-owned bus.
    • Capital: Minimum 5,000 TL capital for legal entities; no capital requirement for real persons, and a 75% discount is applied for applications with a single vehicle.

🚚 Freight and Goods Transportation (C, K Type Authorization Documents)

Type C (International and Domestic Goods Transportation)

  • C1 Authorization Document (Private Goods): Issued to companies carrying their own goods related to their main field of activity internationally and domestically.
    • Capacity: At least 1 self-owned unit vehicle.
    • Capital: No capital requirement.
  • C2 Authorization Document: Has been removed and completely replaced by the L2 authorization document.
  • C3 Authorization Document (International Home/Office Moving): International commercial home-to-home moving.
    • Capacity: At least 3 self-owned unit vehicles and a total capacity of at least 75 tons.
    • Capital: Minimum 25,000 TL capital.

Type K (Domestic Goods Transportation)

  • K1 Authorization Document (Domestic Commercial Goods): General goods/freight transportation for commercial purposes.
    • Capacity: At least 1 unit vehicle and 25 tons for real persons; at least 2 unit vehicles and 50 tons capacity for legal entities (companies). (Pickup trucks are not taken into account in the minimum tonnage calculation).
    • Capital: Minimum 10,000 TL operating capital.
    • Exemption: Those who will transport only with pickup trucks (K1*) are exempt from tonnage, 1 vehicle is sufficient, and a 75% discount is applied to the document fee. Those with special purpose vehicles (K1Ö) are exempt from the minimum capacity other than a single vehicle.
  • K2 Authorization Document (Private Goods): Issued to companies carrying their own goods related to their main activity and not doing commercial shipping.
    • Capacity: At least 1 self-owned unit vehicle.
    • Capital: No capital requirement. (K2* document is 75% discounted for those who only have pickup trucks).
  • K3 Authorization Document (Domestic Home/Office Moving): Home-to-home moving for commercial purposes.
    • Capacity: At least 2 unit vehicles and a total minimum capacity of 35 tons (pickup trucks are not included in the tonnage calculation).
    • Capital: Minimum 5,000 TL operating capital.
    • Special Condition: All vehicles to be registered must be closed cases. (K3* document is 75% discounted for those who only have pickup trucks).

📦 Logistics, Cargo and Distribution (L, M, P Type Authorization Documents)

Type L (Logistics Operation)

  • L1 Authorization Document (Domestic Logistics): Issued to those who will carry out logistics operations domestically.
    • Capacity: At least 3 unit vehicles and a total capacity of at least 75 tons.
    • Capital: Minimum 75,000 TL capital.
    • Area: At least 500 m² open, closed or vehicle parking area at the center or branch.
  • L2 Authorization Document (International Logistics): International and domestic logistics operations.
    • Capacity: At least 5 unit vehicles and a total capacity of at least 200 tons.
    • Capital: Minimum 300,000 TL capital.
    • Area: At least 1,000 m² logistics-purpose area (at least 100 m² for branches).
    • Experience: It is a legal requirement that the applicant has one of the valid C3, K1, K3, L1, M2, N2, P2 or TİO documents for at least 3 years.

Type M and P (Cargo and Distribution)

  • M1 (Intra-city Cargo) & M2 (Domestic/International Cargo): A BTK license is required under the Authorization Regulation on the Postal Sector. KTY minimum vehicle and capital requirements have been removed.
  • P1 (Intra-city Distribution/Courier) & P2 (Domestic Distribution/Courier): A Postal Sector authorization document from BTK is mandatory. The old number of vehicles and capital requirements in KTY have been removed.

🤝 Agency, Brokerage, Warehouse and Organization (F, G, H, N, TİO Authorization Documents)

Type F (Passenger Agency)

  • F1 Authorization Document (Domestic): A capital of at least 2,000 TL on a district basis; at least 6,000 TL in the provincial center is mandatory. No capital is required in villages and towns, and the document fee is 75% discounted.
  • F2 Authorization Document (International): Minimum 6,000 TL capital.

Type G (Goods and Cargo Agency)

  • G1 (Domestic Goods Agency): At least 20,000 TL capital and a 20 m² independent office.
  • G2 (International Goods Agency): At least 30,000 TL capital and a 20 m² independent office.
  • G3 (Domestic Cargo Agency): At least 20,000 TL capital and a 20 m² independent office. (The G3* document can be obtained without capital in provincial areas outside metropolitan cities, and it is 75% discounted).

Type H (Goods Brokerage)

  • H1 (Domestic): Independent office with at least 20,000 TL capital.
  • H2 (International): Independent office with at least 40,000 TL capital.

Type N (Transport Warehouse Operation)

  • N1 Authorization Document (Intra-city Transport Warehouse):
    • Capacity: At least 3 unit vehicles.
    • Capital: At least 15,000 TL capital.
    • Area: At least 75 m² closed, loading/sorting area within the central provincial borders.
  • N2 Authorization Document (Domestic Transport Warehouse):
    • Capacity: At least 10 unit vehicles and a total capacity of at least 400 tons.
    • Capital: Minimum 40,000 TL capital.
    • Area: At least 150 m² closed area and organization in at least 2 geographical regions, at least 2 provinces in each region.

TİO (Transport Affairs Organization)

  • TİO Authorization Document: It is an integrated brokerage document covering road, maritime, rail, and air transport. (It has been legally removed from the KTY and is regulated according to the independent "Transport Affairs Organization Regulation".)
    • Capital: A fixed minimum capital requirement of 1,000,000 TL is sought.

🏢 Terminal Operation (Type T Authorization Documents)

  • T1 Authorization Document (Metropolitan Passenger Terminal): At least 300,000 TL capital and at least 2,000 m² facility area conforming to standards.
  • T2 Authorization Document (Non-Metropolitan Passenger Terminal): At least 100,000 TL capital and at least 2,000 m² area (In districts with a population under 50,000, the area requirement is applied as 500 m²).
  • T3 Authorization Document (Goods/Cargo Terminal): At least 100,000 TL capital and at least 2,000 m² area.
  • (No capital requirement is sought in terminal authorization documents from public institutions and organizations).

⚠️ Common Application Rules and Document Cancellation Risks

In order to maintain legal compliance in road transport and prevent the cancellation of documents, it is a legal obligation to fully implement the following 4 basic rules:

1. Employment of Professional Competence Manager (ÜDY & ODY)

According to the regulation, it is mandatory to employ personnel holding managerial documents in certain commercial documents:

  • Those Where ÜDY and ODY Employment is Mandatory (B1, D1, L2, M2, N2, P2, TİO, T1): In these documents, at least 1 Senior Manager (ÜDY) and 1 Middle Manager (ODY) certificated personnel must be employed.
  • Those Where Only ODY Employment is Mandatory (B2, D2, C3, K1-Legal, K3, L1, M1, N1, P1, T2, T3): Employment of at least 1 relevant type of Middle Manager (ODY) is a legal obligation. (While the domestic logistics L1 authorization document requires only ODY; the international logistics L2 document requires both ÜDY and ODY).
  • Exception: From the K1 authorization document holders registered as a sole proprietorship, if the number of registered vehicles is 1, the condition of employing a manager is not required.

2. SRC and Psychotechnical Status of Drivers

Commercial vehicle drivers must have the relevant SRC certificate and an active Psychotechnical Evaluation Report. In the event of any accident, the lack of these documents of the driver invalidates the insurance and comprehensive policies and causes the compensation to be recoursed (reflected back) to the company.

3. U-ETDS Data Notifications

All authorization document holders performing transportation (passenger and commercial goods transporters) are obliged to report the data regarding the vehicle, driver, passenger, or cargo on the voyage instantly to the Ministry's U-ETDS system.

4. 540-Day Rule in Loss of Minimum Capacity

  • 90-Day Period: If the minimum capacity is lost in case of vehicle sale or total loss, this deficiency must be remedied within 90 days. If not remedied, the document is temporarily suspended.
  • 540-Day Limit: During the 5-year validity period of an authorization document, if the total number of days falling below the minimum capacity due to a lack of vehicles exceeds 540 calendar days (approximately 1.5 years), the authorization document is ex officio canceled by the Ministry.

💡 Conclusion and Strategic Recommendations

Avoiding legal risks in the transport and logistics sector is not a formality but the main pillar of business sustainability. Considering the authorization document fees and administrative fines that increase exponentially every year with the YDO, it will provide legal and financial protection for the current authorization document holders to:

  1. Keep their UETS accounts strictly under control,
  2. Periodically audit Psychotechnical and SRC documents,
  3. Regularly track ODY/ÜDY employment periods via e-Government.

It is strongly recommended that you periodically align your operational processes according to the current conditions of the legislation and check official institution sources at the slightest authorization document and capacity change.