Payroll & SGK Incentive Compliance Auditor

What it does

The Payroll & SGK Incentive Compliance Auditor reviews a payroll/SGK period as an independent second-line review. In the IIA Three Lines of Defense model it plays the second line: it does not accept the first line's (payroll operations) output, it reproduces it from scratch.

Its core technique is substantive recalculation (the strongest, auditor-derived evidence in the ISA 500 hierarchy): for each insured employee it independently computes the premium base (SPEK), employee/employer premiums, income and stamp tax, and the incentive amount, then compares against what payroll reported — any deviation is a finding. The floor ≤ SPEK ≤ ceiling bound is checked (the 2026 ceiling is 9× the minimum wage), flagging both under-declaration below floor and excess above ceiling. Cross-foot/reconciliation ties line totals to the APHB total, period to period, and APHB to the withholding return (MUHSGK combined declaration).

On the incentive side, each code (05510 / 06111 / 07103) runs an eligibility decision tree under AND logic: profile match, the added-employment test (the most common clawback cause — exit/entry mirroring), the debt/collusion gate, APHB law-and-document-type correctness, and duration/counter. A single failing condition voids the incentive retroactively, triggering clawback + late-payment surcharge + administrative fine risk.

Findings are scored with a risk rubric (Amount × Probability × Duration, weighted) and collapsed into a 0-100 Compliance Score. Per Turkish data-protection law (KVKK art. 4-5), national ID and IBAN are masked in output.

When to use it

• "Is the incentive applied correctly", "is this employee eligible for 6111", "is there clawback risk".
• New hires requiring an added-employment test (suspected exit→entry manipulation).
• After a rate/sector change (e.g. the 2026 cut of the non-manufacturing 5510 reduction to 2 points) to verify payroll matches the new parameter.
• Pre-audit before an SGK inspection / administrative fine, accountant second-eye review, period-close reconciliation.

Boundary: a decision-support / pre-audit tool, not an official SGK/accountant opinion or legal advice.

Method / frameworks

• IIA Three Lines of Defense — independent second-line control.
• ISA 500 — recalculation — recompute from scratch (most reliable evidence).
• Reconciliation / cross-foot — line↔total, period↔period, APHB↔withholding.
• Eligibility decision tree (AND) — per-incentive-code conditions.
• Risk-based prioritization — Amount × Probability × Duration materiality.
• KVKK 6698 art. 4-5 — data minimization + PII masking.
• Legal canon: Law 5510 art.81, 6111, 7103, 4857.