Law No. 7552 on Climate (“Law”), which establishes a national legal framework for combating climate change, entered into force upon its publication in the Official Gazette on 9 July 2025. This Law sets out an integrated approach to carbon pricing mechanisms, greenhouse gas (“GHG”) emissions reduction, and climate change adaptation, in line with Turkey’s net-zero emissions target.
The Law offers a comprehensive structure encompassing planning, implementation, financing, and oversight, while leaving detailed technical regulations to be addressed through secondary legislation.
Emissions Trading System
For the first time in Turkey, the Law foresees the establishment of a national Emissions Trading System (“ETS”). Within the emission caps to be determined by the Climate Change Authority (“Authority”), emission allowances will be allocated to businesses, and these allowances will be tradable in the ETS market. The system will be operated by the Energy Markets Operating Company (“EPIAS”).
Entities covered by the ETS must obtain GHG emission permits from the Authority for activities causing emissions and are required to surrender allowances corresponding to their verified annual emissions. Non-compliance with this obligation will result in financial penalties and additional allowance surrender requirements. Permits must be obtained within three years; however, a temporary exemption has been granted to businesses operating during this transitional period. Under this one-time exemption, companies are deemed to have valid emission permits for the first three years to continue operating under the ETS.
Voluntary Carbon Markets and Offset Mechanisms
The Law allows a portion of ETS compliance obligations to be offset using carbon credits. Accordingly, the Authority is authorized to establish a national carbon crediting system, certify offset projects, and maintain relevant registries.
Project owners who submit false or misleading carbon credit declarations may face monetary penalties, and such credits will be deemed invalid.
Carbon Border Adjustment Mechanism
The Law introduces a Carbon Border Adjustment Mechanism (“CBAM”) to regulate embedded carbon emissions in imported products. This mechanism is expected to mirror the European Union’s CBAM and will be coordinated by the Ministry of Trade. The aim is to impose equivalent carbon costs on imported goods as those borne by domestic producers—thus preventing carbon leakage and ensuring fair competition.
Planning and Adaptation Obligations
The Law mandates the development of planning tools such as nationally determined contributions (“NDCs”), local climate action plans, strategic documents, and sectoral risk assessments. Both central and local administrations are required to implement necessary measures by considering climate mitigation and adaptation targets in their planning processes.
Additionally, Provincial Climate Change Coordination Boards are to be established and assigned responsibility for preparing and implementing local climate action plans.
Carbon Pricing and Green Financing
Alongside carbon pricing mechanisms, the Law promotes climate-friendly investments. Revenues from the ETS, carbon credits, and administrative fines will be earmarked under the Authority’s budget to fund green transformation, technology development, R&D, and just transition initiatives. The establishment of the Turkish Green Taxonomy is also regulated under this scope.
Enforcement and Administrative Sanctions
The Law introduces significant administrative penalties for violations. In particular, failure to meet ETS obligations may result in fines of up to twice the market value per missing allowance, and in some cases, emission permits may be revoked.
Fines range from TRY 120,000 to TRY 50,000,000 depending on the severity of the violation and may increase in the event of repeated non-compliance. Enforcement authority lies with the Climate Change Authority.
With the enactment of the Climate Law, Turkey now has a solid legal foundation for low-carbon development. Secondary legislation and sector-specific guidelines are expected to be issued in the coming period.
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