The Turkish Emissions Trading System Regulation (the “Regulation”), published in the Official Gazette dated 27 August 2026 and numbered 33353, sets out the procedures and principles governing the monitoring, reporting and verification of greenhouse gas emissions and the implementation of the Turkish Emissions Trading System (“ETS”). The Regulation entered into force on the date of its publication and repealed the Regulation on the Monitoring of Greenhouse Gas Emissions.
What Does the Regulation Provide?
The ETS is a market-based system that operates on the principle of setting a cap on greenhouse gas emissions in line with the net-zero target and aims to incentivise greenhouse gas emission reductions through the trading of allowances. An allowance, one of the key elements of the system, represents the right to emit one tonne of carbon dioxide equivalent. Operators covered by the ETS are required to surrender allowances corresponding to the verified greenhouse gas emissions of each installation.
A portion of the allowances may be allocated to operators free of charge in accordance with the principles set out in the Regulation. Allowances may also be offered for sale on the primary market and traded on the secondary market. Accordingly, operators may meet their surrender obligations using the allowances they hold and may obtain any additional allowances they require from the market.
Transactions relating to the issuance, holding, transfer and surrender of allowances are carried out electronically through the Registry System.
Entities Subject to the ETS
Installations are categorized based on their annual greenhouse gas emissions conservatively calculated according to their installed capacity. Accordingly, installations with annual emissions exceeding 50,000 tons of CO₂ equivalent and up to and including 500,000 tons of CO₂ equivalent are classified as Category B installations, while installations with annual emissions exceeding 500,000 tons of CO₂ equivalent are classified as Category C installations. Category B and Category C installations are subject to the ETS.
Category A installations, with annual emissions of up to and including 50,000 tons of CO₂ equivalent, are not covered by the ETS. However, Category A installations carry out activities subject to greenhouse gas emissions monitoring under the Regulation remain subject to monitoring, reporting and verification obligations.
Installations where research, development and testing activities are carried out, installations exclusively using biomass and military units are outside the scope of the Regulation. Installations belonging to schools, universities, hospitals and defense industry organizations are outside the scope of the ETS in respect of the relevant activities but remain subject to obligations to monitor, report and verify their emissions.
Key Obligations of Operators
Greenhouse gas emissions permit: Operators covered by the ETS are required to obtain a greenhouse gas emissions permit from the Directorate of Climate Change (the “
Directorate”) to carry out activities that cause greenhouse gas emissions. As a rule, operators with multiple installations must obtain a separate permit for each installation; however, a single permit may be obtained for multiple installations located at the same address. A greenhouse gas emissions permit is valid for five years.
Monitoring, reporting and verification: Operators subject to greenhouse gas emissions monitoring under the Regulation are required to prepare a greenhouse gas emissions monitoring plan and monitor their emissions in accordance with this plan. Operators must report their emissions and activity levels for the preceding calendar year to the Directorate by 30th of April each year. The greenhouse gas emissions report must be verified by a verification body before it is submitted to the Directorate.
Surrender of allowances: Operators covered by the ETS must surrender, through the Registry System, allowances corresponding to the emissions stated in their verified greenhouse gas emissions reports by the last business day of November in the relevant compliance year. Any allowances not surrendered by the applicable deadline will constitute a compensation-year obligation and will be added to the number of allowances required to be surrendered in the following compliance year.
Transitional Period and Sanctions
The ETS will commence with a pilot phase, the scope, duration and implementation procedures and principles of which will be determined by the Carbon Market Board.
Operators that will fall within the scope of the ETS are required to obtain a greenhouse gas emissions permit within three years from the date on which Climate Law No. 7552 entered into force.
The Regulation provides for administrative fines in the event of non-compliance with the applicable obligations. Failure to submit a verified greenhouse gas emissions report within the prescribed period and carrying out activities without obtaining a greenhouse gas emissions permit or without a valid permit are subject to administrative fines.
In addition, the intentional submission of false, misleading or inaccurate information, documents or declarations in connection with matters and procedures governed by the Regulation, as well as failure to fulfil the allowance surrender obligation, are among the grounds requiring the cancellation of the greenhouse gas emissions permit.