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Climate Law Passed by the Grand National Assembly of Türkiye

The Climate Law (“Law”), which sets forth the principles governing climate change mitigation and adaptation, has been adopted by the Grand National Assembly of Türkiye (“TBMM”). The Law will enter into force upon its publication in the Official Gazette.

Aligned with the vision of green growth and the 2053 net-zero emissions target, the Law establishes the fundamental principles for reducing greenhouse gas (GHG) emissions, adaptation to climate change, related planning and implementation tools, revenue sources, permitting and inspection mechanisms, and the legal and institutional framework.

Entities Subject to the Law and Their Obligations

  • All public institutions as well as natural and legal persons are obliged to comply in a timely manner with the measures and regulations adopted in the public interest and to ensure their implementation.
  • While preparing the Nationally Determined Contribution, measures shall be adopted in line with the net-zero emissions target, taking into account national development priorities and country-specific circumstances.
  • The Climate Change Directorate shall monitor, on an annual basis, the progress in GHG emission reduction and climate change adaptation activities.
  • Without prejudice to the provisions of the Turkish Personal Data Protection Law, the Directorate shall be authorized to request any data, documents, and information deemed necessary for implementation from public institutions and private entities. The relevant parties are required to provide such data free of charge and within the specified period.


Establishment of the Emissions Trading System (ETS) and Transitional Provisions

  • The Emissions Trading System (ETS) shall be established by the Climate Change Directorate.
  • Operators engaged in activities that directly cause GHG emissions must obtain a GHG Emissions Permit to continue such activities.
  • Entities included in the scope of the ETS are required to surrender annually an amount of allowances corresponding to their verified GHG emissions. Allowances cannot be subject to collateral agreements.
  • A pilot phase shall be implemented prior to the full operationalization of the ETS. During the pilot phase, administrative fines imposed under the Law shall be reduced by 80%.
  • Entities falling under the scope of the ETS must obtain a GHG emissions permit within 2 years following the effective date of the Law.


Administrative Fines and Other Sanctions

1-Failure to submit a verified GHG emissions report within the prescribed period shall be subject to an administrative fine ranging from TRY 500,000 to TRY 5,000,000. Entities subject to the ETS shall be penalized at twice the standard rate.

2-In the event of non-compliance with the rules, prohibitions, or restrictions relating to ozone-depleting substances:

  • Those who use, import, trade, or place such substances on the market shall be fined TRY 2,500,000.
  • Persons or entities providing maintenance or repair services for products/equipment containing such substances shall be fined TRY 250,000.
  • Those violating labeling requirements shall be fined TRY 120,000.

3-In violation of the procedures, principles, prohibitions, or restrictions related to fluorinated greenhouse gases:

  • Those who use, trade, or market fluorinated greenhouse gases shall be imposed an administrative fine of 2,500,000 TRY and shall not be granted a Hydrochlorofluorocarbon (HFC) Control Certificate for a period of 3 to 6 months.
  • Those who import hydrochlorofluorocarbons without quota or in quantities exceeding their quota shall be imposed an administrative fine of 1,000,000 TRY and, in the following year, their quota shall be reduced proportionally to the amount exceeding the quota.
  • Those who fail to comply with the labeling provisions of containers, products, or equipment containing fluorinated greenhouse gases shall be fined 120,000 TRY.
  • Those who fail to submit notifications and reports to the database within the prescribed period or fail to update the data shall be fined 120,000 TRY.
  • Natural and legal persons who intervene in equipment containing fluorinated greenhouse gases or whose operation depends on these gases shall be fined 120,000 TRY.

4-If a verified GHG emissions report is not submitted within the required time in breach of ETS-related procedures or restrictions, accounts shall be restricted to fulfilling delivery obligations only; all other transactions shall be suspended. Submission of the report at a later date shall remove such restrictions but shall not prevent the imposition of administrative fines.

5-Entities operating within the scope of the ETS without a valid GHG Emissions Permit—either due to non-obtainment, expiration, or revocation of the permit—shall be subject to administrative fines as follows:

  • For entities that have submitted a verified annual GHG emissions report, an administrative fine of TRY 5 per ton of CO₂ equivalent emissions shall be imposed, based on the highest annual emissions value stated in the verified reports submitted to the Climate Change Directorate within the preceding 5 years;
  • For entities that have not submitted any verified annual GHG emissions report, an administrative fine ranging from TRY 1,000,000 to TRY 10,000,000 shall be imposed.

6-Entities subject to the ETS that fail to fulfill at least 80% of their annual allowance surrender obligations within the prescribed time period for 3 consecutive years shall have their GHG Emissions Permit revoked and shall be prohibited from obtaining a new permit for a period ranging from 3 to 6 months.

7-An administrative fine of TRY 170,000 shall be imposed on natural persons and private legal entities who fail to comply with the information, document, or data submission obligations stipulated under the Law or who make misleading declarations.

8-Administrative fines prescribed under the Law shall be doubled in case of the first repetition of the same violation within 3 years, tripled for the second and subsequent repetitions.

9-For violations of the Law or secondary legislation enacted thereunder, the Ministry may, on a one-time basis only and for a period not exceeding one year, grant a deadline for rectifying the non-compliant activity. If the violation is not remedied within this period, the activity may be partially or entirely suspended by the Ministry until compliance is achieved. The granting of a deadline or the suspension of the activity shall not preclude the imposition of administrative fines as provided under the Law.

10-The amount of administrative fine to be imposed for each individual violation under the Law shall not exceed TRY 50,000,000.

An administrative lawsuit could be filed against the Directorate for the administrative fines imposed, but filing a lawsuit will not stop the collection of the fine.

Unless otherwise notified by the relevant competent authorities, obligations regarding the preparation and adaptation of legislation and planning instruments related to greenhouse gas emission reduction and climate change adaptation activities shall be fulfilled by the relevant institutions and organizations no later than 31 December 2027, as stipulated by the Law.

You can contact our consultants for more detailed information.