THE REGULATION ON THE TURKISH EMISSIONS TRADING SYSTEM HAS BEEN PUBLISHED
The Regulation on the Turkish Emissions Trading System (“Regulation”), which sets out the procedures and principles governing the implementation of the Turkish Emissions Trading System (“TR ETS”), 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 principles governing the operation of the emissions trading system established under Climate Law No. 7552, including the monitoring, reporting and verification of greenhouse gas emissions, emissions permits, and the allocation and surrender of allowances.
Scope of the Regulation
The Regulation primarily covers fuel combustion installations with a total rated thermal input of 20 MW or more, as well as installations engaged in refining, iron and steel, metals, aluminium, cement, glass, ceramics, paper and the production of certain chemical products.Installations are classified into three categories based on their annual emission levels. Category A installations, with annual emissions of 50,000 tonnes of CO₂ equivalent or less, will remain outside the scope of the TR ETS but will continue to be subject to monitoring, reporting and verification obligations. Category B installations, with annual emissions exceeding 50,000 tonnes and up to 500,000 tonnes of CO₂ equivalent, and Category C installations, with annual emissions exceeding 500,000 tonnes of CO₂ equivalent, will fall within the scope of the TR ETS. Accordingly, operators carrying out activities falling within the scope of the Regulation should first determine their installation capacities and annual emission levels in order to identify the category applicable to them.
Greenhouse Gas Emissions Permit and Allowance Surrender Obligations
Operators falling within the scope of the TR ETS will be required to obtain a greenhouse gas emissions permit in order to continue their activities. Existing operators are required to obtain such permits by 9 July 2028, although this deadline may be extended by up to two years.Operators of Category B and Category C installations will also be required to surrender allowances corresponding to their verified annual greenhouse gas emissions. Allowances may either be allocated free of charge or acquired from the market, while the rates and principles applicable to free allocation will be determined separately by the Carbon Market Board.Verified annual emissions and activity reports must be submitted to the Climate Change Presidency by 30 April of each year, while the relevant allowances must be surrendered by the last business day of November of the relevant compliance year. Operators falling within the scope of the pilot phase are also required to submit their first Monitoring Methodology Plans by 27 October 2026.
Pilot Phase and Sanctions
The implementation of the TR ETS will commence with a pilot phase. The sectors and installations to be covered by the pilot phase will be determined separately by the Carbon Market Board.Under the Climate Law, administrative fines imposed during the pilot phase will be applied at an 80% reduced rate. Significant administrative fines may be imposed in cases where a verified emissions report is not submitted within the prescribed period, activities are carried out without a valid emissions permit, or the allowance surrender obligation is not fulfilled. Payment of an administrative fine imposed for failure to surrender the required allowances within the prescribed period will not release the operator from its obligation to surrender such allowances.
Conclusion
The Regulation establishes the fundamental legal framework for the implementation of Türkiye’s mandatory carbon market. In particular, for operators falling within Category B and Category C, the new system will have direct financial and operational implications in addition to environmental compliance obligations. Accordingly, companies that may fall within the scope of the Regulation should, without waiting for the secondary legislation to be finalised, conduct installation-level assessments of their scope and applicable category, review their emissions data and existing reporting systems, and begin planning their compliance processes in relation to emissions permits and allowance surrender obligations.