İstanbul, Türkiye | Publication | September 2026

Emissions Trading System Regulation Published

Authors: A.Deniz Altınay, Galya Kohen Benbanaste, Selin Orkun

The Türkiye Emissions Trading System Regulation (the “Regulation”) was published in the Official Gazette No. 33353 dated 27 August 2026. The Regulation sets out the procedures and principles governing the implementation of the Türkiye Emissions Trading System (the “ETS”) and the monitoring, reporting and verification of greenhouse gas emissions under Climate Law No. 7552 (the “Climate Law”).

Scope

Under the Regulation, the ETS applies to installations carrying out the activities listed in Annex-1 to the Regulation that fall within the following categories:

  • Category B installations (installations with annual emissions, conservatively calculated based on their installed capacity, exceeding 50,000 tonnes of CO₂ equivalent but not exceeding 500,000 tonnes of CO₂ equivalent, including transferred CO₂ but excluding CO₂ originating from biomass); and
  • Category C installations (installations with annual emissions exceeding 500,000 tonnes of CO₂ equivalent).

Installations belonging to schools, universities, hospitals and defence industry organisations that would otherwise fall within the scope of the Regulation are excluded from the ETS, limited to the activities they carry out. However, their obligations relating to the monitoring, reporting and verification of greenhouse gas emissions will continue to apply.

Greenhouse Gas Emission Permits

Operators within the scope of the ETS are required to obtain a greenhouse gas emission permit from the Directorate of Climate Change (the “Directorate”) in order to continue carrying out activities that result in greenhouse gas emissions. Operators with multiple installations must obtain a separate permit for each installation.

Greenhouse gas emission permits will be valid for 5 years, and operators will be required to apply for renewal at least 6 months before the expiry of the relevant permit. In addition, certain changes relating to the installation, its category or the permit holder must be notified to the Directorate within 30 days.

As part of the transition process, operators that will be included in the ETS must obtain a greenhouse gas emission permit within 3 years from the date on which the Climate Law entered into force. To enable operators to continue their activities during this period, they will be deemed, on a one-off basis, to hold the required emission permit.

Emission Allowance System and Allowance Surrender Obligations

The ETS cap will be announced under the National Allocation Plan published in the Official Gazette within 60 days following the deadline for submission of verified greenhouse gas emission reports covering the relevant scheme year.

Emission allowances will be issued in book-entry form through the Registry System and may be made available to operators through sale on the primary market or by way of free allocation.

Operators wishing to benefit from free allocation must submit an electronic application to the Directorate within 30 days following the publication of the National Allocation Plan.

Operators within the scope of the ETS, must surrender, through the Registry System, allowances corresponding to the amount of verified greenhouse gas emissions of each installation by the last business day of November of the relevant compliance year. Failure to fulfil the surrender obligation within the prescribed period will result in the sanctions stipulated under the Climate Law, and any shortfall in surrendered allowances will be added to the operator’s surrender obligation for the following year.

Monitoring, Reporting and Verification Obligations

Operators carrying out activities listed in Annex-1 must monitor their greenhouse gas emissions in accordance with a monitoring plan approved by the Directorate. Operators are required to report their greenhouse gas emissions and activity levels for the preceding calendar year to the Directorate by 30 April of each year. Where deemed necessary, the Directorate may extend this deadline by up to one month.

Greenhouse gas emission reports must be verified before being submitted to the Directorate. As a rule, verification will be carried out by accredited verification bodies appointed through the Central Electronic Verifier Organisation Assignment System (“MEDAS”).

Pilot Phase

The ETS will commence with a pilot phase. The principle of commencing with a pilot phase is consistent with the previously published draft regulation. However, the draft regulation had expressly designated 2026-2027 as the pilot period and stipulated that operators would receive 100% free allocation, that flexibility mechanisms through carbon credits would not be available, that allowances could only be used to fulfil pilot period obligations, that market transactions would continue until 30 April 2029, and that administrative fines would be reduced by 80%. The Regulation does not include these details and instead delegates the determination of the scope, duration and implementation of the pilot phase to the Carbon Market Board. Activities relating to the transmission and storage of natural gas and crude oil are excluded from the ETS until the end of the first implementation period, limited to such activities, except for the monitoring, reporting and verification requirements, which will continue to apply.

Administrative Sanctions

The Regulation provides for administrative monetary fines, varying according to the category and emission level of the relevant installation, for violations such as failure to submit emission reports within the prescribed period, operating without an emission permit, or continuing operations under an expired or revoked permit. The Regulation has entered into force on the date of its publication, 27 August 2026.iyesine göre değişen idari para cezaları öngörmektedir. Yönetmelik, yayımlandığı 27 Ağustos 2026 tarihinde yürürlüğe girmiştir.