DECISION BRIEF
What the rule requires
Climate Law No. 7552 was published and entered into force on 9 July 2025 (Resmî Gazete 32951). It creates the national emissions trading system, the Carbon Market Board, greenhouse gas emission permits, annual allowance surrender and an administrative penalty regime.
The Climate Change Directorate published the draft Türkiye Emissions Trading System Regulation for consultation on 22 July 2025; comments closed on 4 August 2025. Under the draft the pilot period covers 2026 and 2027 and applies to installations in the SKDM/CBAM sectors — iron and steel, aluminium, cement, fertiliser and electricity generation — with annual emissions above 50,000 tonnes of CO2 equivalent, reaching 41% of national emissions, with 100% free allocation on a benchmarking method. The first implementation period of 2028–2035 would extend scope to the Annex 1 activities, reaching 47%. The regulation is still a draft and is not in force.
Who is affected, and from when
Built for: Operators of large direct-emitting installations — iron and steel, aluminium, cement, fertiliser, power generation — and the compliance, energy and finance teams accountable for them.
Installations carrying out the direct-emitting activities to be listed in secondary legislation must obtain a greenhouse gas emission permit from the Climate Change Directorate under Article 9(3). Provisional Article 1(2) gives them three years from 9 July 2025 — until 9 July 2028 — and deems the permit to exist once during that window, extendable by up to two years on a Carbon Market Board decision.
Installations inside the ETS must surrender allowances each year equal to their verified annual emission figure (Article 9(5)).
The penalties are specific. Failing to submit the verified greenhouse gas emission report on time carries an administrative fine of TRY 500,000 to TRY 5,000,000, doubled for ETS installations (Article 14(1)). Operating without a valid permit costs TRY 5 per tonne of CO2 equivalent applied to the highest verified report submitted in the last five years, or TRY 1,000,000 to TRY 10,000,000 where there is no verified report (Article 14(4)(b)). These are the statutory base amounts and are revalorised annually — the communiqué published on 27 December 2025 raised them by 25.49% for 2026. During the pilot phase fines are reduced by 80% (Provisional Article 1(1)).
Separately, planning instruments under Articles 5 and 6 and local climate action plans are due by 31 December 2027 (Provisional Article 2).
What to do next
- Establish whether your installation performs a listed direct-emitting activity and clears 50,000 tCO2e a year — that is what decides pilot membership under the draft.
- Build installation-level monitoring for calendar 2026 now. The pilot is the cheap place to get it wrong: fines are cut by 80% while it runs.
- Appoint a verifier and budget for annual verification as a standing cost, not a project.
- If you also export to the EU, run one monitoring system for both. A carbon price paid here is deductible against CBAM, so the domestic cost is not additive — see the CBAM hub.
- Treat the secondary legislation as live: the activity list, allocation rules and MRV detail all sit in regulations that are still being finalised, and this page tracks them below.
Coverage boundary
We do not restate parts of the draft regulation as if they were in force, and voluntary carbon markets and offsets are outside this hub.