Regulation on the Turkish Emissions Trading System Published
The Regulation on the Turkish Emissions Trading System (the Regulation) was published in the Official Gazette dated 27 August 2026 and numbered 33353 and entered into force on the same date. The Regulation sets out the procedures and principles regarding the monitoring, reporting and verification of greenhouse gas emissions and the implementation of the Turkish Emissions Trading System (TR ETS). The Regulation repealed the Regulation on the Monitoring of Greenhouse Gas Emissions, published in the Official Gazette dated 17 May 2014 and numbered 29003.
The key matters addressed under the Regulation are summarized below:
Scope of the TR ETS
Annex-1 to the Regulation lists various activities meeting certain capacity thresholds, including fuel combustion, petroleum refining and the production of iron and steel and other metals, clinker, glass, ceramics, paper and cardboard, and various chemicals.
Installations carrying out these activities are divided into three categories based on their annual emissions conservatively calculated according to their installed capacity, excluding carbon dioxide (CO₂) emissions from biomass and including transferred CO₂. Accordingly, installations with annual emissions of:
- 50,000 tons of CO₂ equivalent or less are classified as Category A;
- more than 50,000 tons and up to and including 500,000 tons of CO₂ equivalent are classified as Category B; and
- more than 500,000 tons of CO₂ equivalent are classified as Category C.
The TR ETS covers Category B and Category C installations. Although Category A installations fall outside the scope of the TR ETS, they are subject to monitoring, reporting and verification obligations. Where an operator carries out any activity listed in Annex-1, its other activities listed in Annex-1 are also included within the scope of the Regulation irrespective of their capacity. Installations or parts of installations used for research and development or testing activities, or exclusively using biomass, fall outside the scope of the Regulation. Installations belonging to schools, universities, hospitals and defense industry organizations are excluded from the TR ETS, without prejudice to their monitoring, reporting and verification of obligations.
Greenhouse Gas Emission Permit
Operators within the scope of the TR ETS are required to obtain a greenhouse gas emission permit from the Directorate of Climate Change (the Directorate) to carry out activities that cause greenhouse gas emissions. Permit applications are submitted electronically and, as a rule, on an installation basis. Greenhouse gas emission permits are valid for five years.
Pursuant to Law No. 7552 on Climate (the Law), operators within the scope of the TR ETS are required to obtain a greenhouse gas emission permit within three years from 9 July 2025, the date on which the Law entered into force. During this period, operators are deemed, on a one-time basis, to hold a greenhouse gas emission permit. If deemed necessary, this period may be extended by the Directorate for up to two years pursuant to a decision of the Carbon Market Board (the Board).
ETS Cap, Allowances and Market Operation
The TR ETS cap is determined based on an emissions-intensity approach and is set out in the National Allocation Plan, which specifies the cap and the distribution of allowances. Allowances are issued in the Registry System, where transactions relating to allowances are electronically recorded, and are made available through the primary market and/or allocated free of charge.
Free allocation is based on the benchmarking method for sub-installations, and the amount of free allocation is determined separately for each sub-installation. Operators seeking free allocation are required to apply to the Directorate following the publication of the National Allocation Plan.
Allowances are offered for sale on the primary market in accordance with the auction calendar determined by the Directorate, while market participants may trade allowances on the secondary markets. Operators are required to surrender allowances corresponding to their verified greenhouse gas emissions through the Registry System. The Regulation also provides for market stability and flexibility mechanisms and allows carbon credits generated from projects implemented in Türkiye to be used, at specific rates, to meet allowance surrender obligations.
Monitoring, Reporting and Verification
Operators carrying out activities within the scope of Annex-1 are required to prepare a greenhouse gas emissions monitoring plan and submit it to the Directorate for approval at least six months before greenhouse gas emissions are first monitored.
Operators must report their greenhouse gas emissions and activity levels for the preceding calendar year to the Directorate by 30 April each year. Greenhouse gas emission reports must be verified by accredited verification bodies assigned through the Central Electronic Verification Body Assignment System (Merkezi Elektronik Doğrulayıcı Kuruluş Atama Sistemi – MEDAS) before being submitted to the Directorate.
Operators are required to retain all data and information records within the scope of the Regulation for at least 10 years.
Pilot Phase and Transitional Period
The TR ETS commences with a pilot phase, the scope, duration and implementation principles of which will be determined by the Board. Operators covered by the pilot phase are required to submit their first Monitoring Methodology Plans electronically to the Directorate within two months following the entry into force of the Regulation (by 27 October 2026, unless the deadline is extended). If deemed necessary, the Directorate may extend this period by up to six months.
The first implementation period of the TR ETS consists of two sub-periods. Activities relating to the transmission and storage of natural gas and crude oil are excluded from the scope of the TR ETS until the end of the first implementation period, without prejudice to the applicable monitoring, reporting and verification obligations.
Sanctions
In the event of a breach of the obligations under the Regulation, the administrative sanctions stipulated under Article 14 of the Law apply. Failure to submit a verified greenhouse gas emission report within the prescribed period is subject to an administrative fine ranging from TRY 627,450 to TRY 6,274,500, depending on the installation category and emission amount. These fines are imposed at twice the applicable amount for operators within the scope of the TR ETS.
Operators within the scope of the TR ETS that continue their activities without obtaining a greenhouse gas emission permit or with an expired or revoked permit are subject to an administrative fine ranging from TRY 1,254,900 to TRY 12,549,000, depending on the installation category and emission amount.
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