The Long-Awaited Climate Law Has Entered Into Force

I. INTRODUCTION

The Climate Law No. 7552 (the "Law") was published in the Official Gazette dated July 9, 2025 and numbered 32951, and entered into force with immediate effect. The Law provides a legal basis for combating climate change in line with the vision of green growth and the goal of net-zero emissions. In this context, the Law covers:

• greenhouse gas emission reduction and climate change adaptation activities;
• planning and implementation tools;
• revenues;
• permitting and supervision; and
• the procedures and principles regarding the legal and institutional framework for the above.

The Law introduces many new concepts into Turkish legislation, such as the Turkish green taxonomy, carbon pricing instruments, carbon credits, and climate justice.

The Law represents a significant development in the field of climate protection law in Türkiye.

II. CLIMATE CHANGE MITIGATION ACTIVITIES

1. Climate change mitigation activities are addressed under two subcategories: greenhouse gas emission reduction and climate change adaptation.
2. Greenhouse gas emissions will be reduced in accordance with the nationally determined contribution (i.e., a document periodically prepared under the coordination of the Climate Change Authority (the "Authority") with the cooperation of relevant institutions, containing Türkiye's emission reduction and adaptation targets and commitments in line with international agreements and standards), the net-zero emissions target, and the strategies and action plans issued or updated by the Authority. Relevant public institutions may introduce regulations for the implementation of emission reduction activities. Institutions and organizations will be responsible for implementing emission reduction measures aligned with the net-zero emissions target and the circular economy approach, to be applied in sectors included in the nationally determined contribution. These include:
   1. energy, water, and raw material efficiency,
   2. prevention of pollution at its source,
   3. increasing the use of renewable energy,
   4. reducing the carbon footprint of products, businesses, institutions, and organizations,
   5. use of alternative clean or low-carbon fuels and raw materials,
   6. expansion of electrification,
   7. development and increased use of clean technologies,
   8. establishment of a zero-waste system ensuring the application of such measures in line with just transition principles, and
   9. enforcement and monitoring of these practices.
3. Similarly, relevant public institutions may adopt regulations for adaptation activities aimed at preventing or minimizing existing or potential losses and damages related to climate change or leveraging opportunities.

III. PLANNING AND IMPLEMENTATION TOOLS

1. In plans, programs, strategies, action plans, and other policy documents prepared by institutions and organizations, strategies and action plans published by the Authority, as well as the principles set out in this Law, shall be taken into account in line with the green growth vision and the net-zero emissions target.
2. The Law outlines the principles for implementation tools such as climate changerelated financing, technology development and transfer, and capacity-building activities. For example:
   1. Climate financing and incentive resources for climate change mitigation will be developed and utilized; insurance instruments will be developed; green and sustainable capital market instruments, bank financing, and other financial tools will be encouraged.
   2. The Turkish Green Taxonomy will be established to define the principles and criteria for economic activities contributing to climate action, thereby mobilizing climate finance.
   3. A Carbon Border Adjustment Mechanism may be established to manage the embedded greenhouse gas emissions of products imported into the Turkish Customs Territory.

IV. EMISSIONS TRADING SYSTEM

1. An Emissions Trading System (the "ETS") will be established by the Authority. The ETS is a market-based mechanism that operates on the principle of setting an upper limit on greenhouse gas emissions compatible with the net-zero target and incentivizes emission reductions through trading of allowances¹. A national allowance plan will be prepared by the Authority, and allowance distribution will be carried out. The Energy Markets Operation Corporation has been designated as the market operator.
2. Activities that directly cause greenhouse gas emissions will be determined by regulation within the scope of the ETS. A greenhouse gas emission permit from the Authority will be mandatory to carry out these activities. Businesses within the ETS will be required to surrender annual allowances equivalent to their verified annual greenhouse gas emissions. Administrative fines will be imposed for failure to submit allowances on time.
3. The ETS may allow offsetting of a portion of allowance obligations with an equivalent amount of carbon credits, permitting the use of carbon credits within the ETS. The Authority will determine the principles for the use and generation of carbon credits and the establishment and implementation of the national carbon crediting system.
4. A pilot phase will be implemented before the full application of the ETS.

V. SANCTIONS FOR NON-COMPLIANCE

1. Administrative fines are foreseen for non-compliance with obligations under the Law. Fines will be progressively increased in case of repeated violations. The maximum fine per violation is capped at 50 million Turkish Lira..
2. In case of non-compliance with obligations under the Law and its regulations, the Ministry of Environment, Urbanization and Climate Change may, only once and for a period not exceeding one year, grant a deadline for the activity to be brought into compliance. If the non-compliance continues at the end of this period, the activity in question may be partially or entirely suspended until the issues are resolved. Granting time or suspending activity does not prevent the imposition of administrative fines stipulated in the Law.

VI. INSPECTION

The Authority is authorized to conduct inspections related to acts subject to administrative sanctions due to non-fulfillment of obligations under the Law. Relevant parties must:

• provide the necessary environment for inspections;
• submit all requested documents and information to the Authority or the authorized inspection body, including raw materials, fuels, products, and wastes used in activities that may contribute to climate change, emission volumes, emergency plans, monitoring systems, greenhouse gas emission reports, and other data; and
• facilitate inspections and bear the costs of any analyses or measurements conducted by the authorities.

VII. CONCLUSION

The Law was published in the Official Gazette on 9 July 2025 and entered into force with immediate effect.

It appears that the Law defers the regulation of many key issues, including the ETS, to secondary legislation. Therefore, for many important issues such as which companies should obtain greenhouse gas emission permits for their activities or what the principles and criteria of the Turkish Green Taxonomy will be that will contribute to the mobilization of climate finance, legislative developments will need to be followed in order to act in the direction of sustainable development and to avoid administrative sanctions.

Footnote

1 It refers to a fungible, transferable, and dematerialized right to emit one ton of carbon dioxide equivalent of greenhouse gases for a specified period.

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