Abstract
Turkey offers foreign investors a large and diversified energy market, substantial renewable resources, a strategic position between producing and consuming regions, and a regulatory system that combines market liberalization with close administrative supervision. The opportunity is real, but an energy investment is not made bankable by resource quality alone. Corporate structure, licensing, connection capacity, land rights, environmental approvals, construction, offtake, currency exposure, financing security and change-of-control rules must operate as one legal architecture.
This article explains the 2026 framework governing investment in electricity, renewable energy, natural gas and petroleum in Turkey. It focuses on the issues that foreign sponsors, lenders, developers and multinational consumers should examine before committing capital. It also discusses current regulatory developments, selected higher-court rulings, practical due diligence and the role of Turkish energy counsel. Because secondary legislation and EPDK Board decisions change frequently, project-specific verification remains essential at signing, financial close, transfer and commissioning.
Introduction
Turkey's energy sector is regulated through a layered system of primary statutes, Presidential decisions, regulations, communiques, technical codes and EPDK Board decisions. Electricity generation, transmission, distribution, supply, aggregation and storage do not all follow the same legal route. The Electricity Market Law establishes the principal structure and requires a separate analysis for each regulated activity and, in many cases, each facility.1
EPDK also regulates natural gas, petroleum and LPG markets under separate statutes. The Ministry of Energy and Natural Resources, TEIAS, EPİAS, TEDAS, distribution companies, environmental authorities, municipalities, land administrations and sector-specific bodies may each control a different part of the timetable.2
For a foreign investor, the key question is not simply whether foreign ownership is permitted. It is whether the chosen investment vehicle can obtain and maintain the required authorizations, secure grid and land rights, satisfy capital and reporting obligations, finance construction and preserve value through a later refinancing, share transfer or exit. Legal due diligence should therefore begin before exclusivity or site acquisition, not after the commercial terms are fixed.
1. Foreign Investment and Market Entry
1.1 Equal Treatment and the Turkish Project Company
Foreign Direct Investment Law No. 4875 is based on equal treatment between foreign and domestic investors. It does not, however, displace energy-market licensing, merger control, land, environmental, foreign-exchange, sanctions or public-tender rules.3
A foreign sponsor will usually invest through a Turkish project company. For electricity pre-license and license applications, an applicant subject to private law must generally be organized as a joint stock company or limited liability company under the Turkish Commercial Code. If it is a joint stock company, shares other than those traded on a stock exchange must generally be registered shares.4
The company should be formed with the eventual financing and exit in mind. Articles of association, share classes, reserved matters, security rights, sponsor support, transfer restrictions and board composition should be checked against mandatory license conditions. A structure that is efficient for tax or group reporting can still create a regulatory problem if it obscures indirect ownership or prevents timely EPDK approval.
1.2 Acquisition, Joint Venture or Greenfield Entry
A greenfield project gives the investor control over site selection, technology and contracting, but exposes it to connection-capacity, development and permitting risk. Acquisition of an operating or advanced-stage project may shorten the timetable, yet requires careful review of license history, completion milestones, administrative investigations, market-settlement records, land rights, environmental approvals and hidden sponsor obligations.
There is no general rule requiring a Turkish partner. A local partner may nevertheless add development capacity, land access and administrative knowledge. The joint-venture agreement should distinguish matters requiring shareholder consent from matters that the licensed company must decide through its corporate organs. Deadlock, funding default and exit provisions must remain workable without causing an unauthorized direct or indirect change of control.
2. EPDK and the Licensing Architecture
2.1 Pre-License and Generation License
Licensed electricity generation normally begins with a pre-license. The pre-license allows the project company to obtain the approvals, permits, land rights and other prerequisites required before a generation license can be issued. EPDK's current guidance emphasizes that generation begins only after the pre-license obligations have been completed and the generation license has been granted.5
The pre-license period is therefore a development covenant, not a passive reservation of capacity. The sponsor should maintain an integrated conditions-precedent schedule covering zoning, environmental approvals, land acquisition or allocation, construction permits, technical interaction clearances, grid connection, project approval and corporate capital requirements. Delay by one authority can affect deadlines before another.
The generation license identifies the facility, source, installed capacity, location, term and other operative conditions. After licensing, the project remains subject to commissioning milestones, technical compliance, reporting, market-registration and settlement obligations. A license is not merely an asset recorded in a data room. It is a continuing public-law authorization whose breach can lead to warning, administrative fine, suspension, cancellation, forfeiture of security and restrictions on relevant persons.
2.2 Share Transfers, Mergers and Change of Control
Share transfers and changes in control require special attention during the pre-license phase and throughout the licensed life of the project. The Electricity Market Law and Licensing Regulation contain restrictions, approval requirements and exceptions for specified corporate reorganizations. Parties should analyze direct and indirect ownership, mergers, demergers, security enforcement and intra-group transactions before signing.6
An M&A agreement should make regulatory approval a clear condition precedent, allocate responsibility for filings and information, regulate conduct between signing and closing, and address long-stop dates. Warranty protection should cover the accuracy of license disclosures, satisfaction of milestones, absence of unauthorized changes, regulatory correspondence, guarantees, investigations and all facts that could trigger cancellation or monetary liability.
3. Renewable Energy and YEKDEM
3.1 Support for Licensed Renewable Projects
Law No. 5346 establishes the principal statutory basis for renewable-energy support. Presidential Decision No. 7189 applies prices and periods to eligible YEK-certified renewable facilities entering operation from 1 July 2021 through 31 December 2030 and provides for price updates under the formula attached to the Decision.78
The current mechanism should not be reduced to a single headline tariff. Technology, commissioning date, support period, price-update formula, YEK certificate, application timing and market participation all matter. A lender's base case should identify which legal instrument creates each revenue assumption and should include a sensitivity case for delay beyond the intended eligibility date.
Domestic-component support is governed through a separate certification and audit structure. The Ministry's official guidance refers to the Domestic Component Regulation and the schedule attached to Presidential Decision No. 7189. Applications, manufacturing records and verification should be treated as evidence-heavy compliance work rather than a closing assumption.9
3.2 YEKA and Competitive Allocation
Renewable Energy Resource Area, or YEKA, tenders allocate designated resource areas and connection rights under tender specifications and project agreements. The commercial model can differ materially from ordinary licensed development. Bidders must read the current specification, localization or domestic-content obligations, free-market sale period, purchase arrangement, penalties, bid security and performance security as a single package.
A foreign bidder should also test consortium liability, transfer restrictions and the consequences of a change in technology supplier or financing plan. The tender document can impose project-specific duties that are stricter than the general legislation. Those duties must flow down into EPC, equipment supply, O&M and shareholder arrangements.
4. Unlicensed Generation and Corporate Rooftop Solar
The unlicensed regime enables qualifying persons to generate electricity without obtaining a generation license or establishing a company for that purpose. The regime is designed principally around self-consumption, distributed generation and reduced network losses. The permitted categories and detailed conditions are found in Article 14 of Law No. 6446 and the Unlicensed Electricity Generation Regulation.10
A commercial rooftop or on-site solar project still requires legal and technical discipline. The investor should confirm the eligible consumption facility, connection level, grid operator, site rights, structural capacity, project approval, acceptance procedure, metering, monthly settlement, surplus treatment and contractual allocation of curtailment and maintenance risk. Landlord, tenant, roof owner, consumer and financier may not be the same person.
Recent rules reinforce the consequences of missing development and operational steps. A 2024 amendment addresses completion periods and provides that, after commissioning, electricity generated before execution of the system-use agreement can be treated as a contribution to YEKDEM without payment until the network operator disconnects the facility.11
For multinational manufacturers, the value of an unlicensed project is often a combination of energy-cost reduction, operational resilience and sustainability reporting. The contract should therefore address ownership of environmental attributes and certificates, data access, change in law, roof reinstatement, early termination, insurer requirements and the effect of a sale or closure of the associated consumption site.
5. Storage, Aggregation and Smart Metering
Storage and aggregation are changing the commercial map of the Turkish electricity market. A storage-linked investment requires a precise classification of the facility, its relationship to licensed or unlicensed generation, charging source, permitted grid interaction, metering and settlement treatment. The project's model should not assume that every stored unit can be discharged and compensated in the same way.
The amendment published on 29 December 2025 permits storage facilities in specified unlicensed generation projects that have received a call letter, subject to the conditions in the unlicensed-generation framework. It also provides that specified electricity discharged from storage may receive no payment after settlement.12
The aggregation regime allows a licensed aggregator to manage a portfolio of eligible production, consumption and storage resources and participate in relevant markets under the regulatory conditions. Smart-meter and measurement rules support this transition by increasing data granularity, remote communication and settlement capability. Contracts should allocate data access, dispatch authority, imbalance costs, baseline risk and cybersecurity responsibility.13
6. Natural Gas, Petroleum and LPG
6.1 Natural Gas
Natural-gas import, transmission, storage, wholesale, export, distribution and CNG activities are regulated under Law No. 4646 and the Natural Gas Market Licensing Regulation. The licensing category determines capital, technical, contractual and reporting requirements. Distribution has its own tender and regional structure, while import and storage projects also engage infrastructure access and national supply considerations.14
Foreign investors should identify whether the project depends on regulated access to transmission, LNG terminal or storage capacity, and whether capacity rights can be transferred or pledged. Long-term supply, take-or-pay, balancing, quality, interruption and sanctions clauses must align with Turkish licensing and network rules.
6.2 Petroleum and Upstream Activities
Refining, distribution, dealership, storage, transmission and related downstream activities are governed principally by Petroleum Market Law No. 5015 and EPDK's licensing rules. LPG activities are separately regulated under Law No. 5307.15
Upstream exploration and production are governed by Turkish Petroleum Law No. 6491 and the related administrative regime. An investor must distinguish an upstream petroleum right from downstream market licenses, environmental permissions, land access and pipeline or terminal arrangements. Farm-in, joint operating and service agreements should reflect the public-law status of the underlying right.16
7. Land, Environment and Construction
Energy projects often fail at the interface between the license and the site. A complete title review should cover ownership, cadastral boundaries, mortgages, easements, usufruct, leases, treasury or forest status, zoning, protected areas, agricultural restrictions, mining rights and access roads. Grid routes and temporary construction areas can be as important as the generation footprint.
Environmental Impact Assessment requirements arise under the Environmental Law and the current EIA Regulation. The applicable route depends on project type, capacity, location and current annexes. An EIA Positive or EIA Not Required decision does not replace separate environmental permits, zoning, construction or sector approvals.17
EPC and equipment contracts should mirror the regulatory critical path. Completion tests, grid compliance, provisional acceptance, liquidated damages, extension of time and force majeure should refer to the actual public approvals and connection obligations. A generic international form can be useful, but it must be adapted to Turkish permits, tax, labor, localization, import, customs and dispute-enforcement realities.
8. Power Purchase Agreements and Project Finance
A corporate power purchase agreement may support a licensed supplier relationship, renewable procurement or another structure permitted by market rules. The parties should identify who holds the relevant license, how electricity is scheduled and settled, who bears imbalance and curtailment, how metering errors are corrected, and what happens if a consumption site, supplier or generating facility leaves the arrangement.
Currency drafting requires special care. Decree No. 32 and Communique No. 2008-32/34 restrict foreign-currency and foreign-currency-indexed terms in specified contracts between persons resident in Turkey, subject to exceptions and amendments. Parties should not assume that a foreign shareholder, international lender or imported equipment automatically validates the desired PPA pricing clause.18
Project-finance lenders will examine the license, land, grid rights, construction package, revenue regime, accounts, insurances, sponsor support and enforcement path. Security should be mapped asset by asset. Regulatory consent may be needed for share security, transfers or enforcement. Direct agreements should give lenders notice and cure rights without promising an outcome that an authority has not approved.
The base financial model should be tested against delayed commissioning, reduced availability, curtailment, imbalance, inflation, exchange rates, interest rates, equipment replacement, YEKDEM eligibility and change in law. Legal drafting should then allocate the risks that the model identifies rather than repeating generic boilerplate.
9. Higher Court Rulings and Regulatory Litigation
9.1 Constitutional Review of the Electricity Market Law
In E. 2013/65, K. 2014/93, the Constitutional Court reviewed numerous provisions of Electricity Market Law No. 6446. It annulled specified transitional rules while rejecting challenges to other provisions. The decision illustrates that sector reform remains subject to constitutional requirements concerning legality, property, judicial protection and the limits of transitional intervention.19
9.2 Legal Certainty in YEKDEM Recovery
In E. 2024/503, K. 2024/3471, the 13th Chamber of the Council of State considered the recovery of YEKDEM payments connected with production above the registered and accepted capacity. The Chamber recognized the license holder's duty to comply with capacity limits, but held that retrospective recovery lacked a sufficiently clear legal basis for the relevant period where the administrative process had operated with authority participation and no fraud, misleading statement or open error was established.20
The practical lesson is not that capacity limits can be ignored. It is that regulatory enforcement, repayment and retrospective administrative action must rest on a clear legal basis and respect legal certainty. Investors should preserve meter records, EPİAS settlement data, instructions, acceptance documents and all communications that show how the administration operated the relevant process.
9.3 Sanctions Against Indirect Shareholders
In E. 2021/2981, K. 2024/5448, the 13th Chamber reviewed sanctions imposed on an indirect shareholder after cancellation of a generation license. The court upheld the annulment of the measure because the applicable provision listed the license holder, qualifying shareholders and board members but did not provide for sanctions against an indirect shareholder in the circumstances examined.21
For transaction planning, the judgment reinforces the need to identify the precise statutory addressee of a sanction. For compliance, it remains essential to map direct and indirect ownership, board service and historic involvement because current rules and the facts of another case may differ.
10. Due Diligence for a Foreign Energy Investor
- Corporate and ownership. Verify the Turkish project company, shareholder chain, beneficial ownership, capital, board history, related-party arrangements and any regulatory restrictions affecting shareholders or directors.
- Licenses and applications. Review every license, pre-license, amendment, application, deadline, security, inspection, warning, investigation and authority correspondence. Confirm 2026 fees and payment evidence.
- Grid and market. Check connection opinion, capacity allocation, connection and system-use agreements, acceptance, EPİAS registration, metering, settlement, imbalance, curtailment and historical compliance.
- Land and permits. Reconcile title, coordinates, access, zoning, EIA, construction, environmental, forest, agricultural, mining and expropriation records with the licensed project.
- Contracts and finance. Examine EPC, equipment, O&M, PPA, supply, balancing, financing, guarantees, insurance, direct agreements and termination exposure.
- Revenue and incentives. Verify the legal basis for YEKDEM, domestic-component support, YEKA terms, investment incentives, surplus sales and environmental attributes.
- Disputes and compliance. Investigate litigation, arbitration, administrative cases, fines, tax, customs, sanctions, anti-bribery, competition, data protection and labor matters.
EPDK has fixed 2026 pre-license, license, amendment and annual license fees by Board Decision No. 14051. The amounts and payment route should be checked for the particular application rather than copied from an earlier closing checklist.22
11. When to Instruct an Energy Lawyer in Turkey
Turkish energy counsel should be engaged before an investor signs exclusivity, acquires land, files a license application, commits to equipment or promises a financing timetable. Early advice can distinguish an investable project from one whose connection, site or authorization assumptions are not legally aligned.
A foreign investor searching for an energy lawyer in Turkey should look for experience with EPDK licensing, project development, M&A, administrative law, project finance, construction, offtake and regulatory litigation. Counsel should be able to work from the technical project schedule, not only the corporate documents, and should monitor the current EPDK legislation list and Board decisions.23
Foreign shareholder documents may require Turkish equivalents, apostille or consular legalization and certified translation. The engagement should allocate responsibility for corporate documents, authority filings, technical annexes, translations, regulatory meetings, transaction conditions, financing deliverables and post-closing compliance.24
Frequently Asked Questions
Can a wholly foreign-owned company hold an electricity generation license in Turkey?
Yes, foreign ownership is not generally prohibited. The licensed applicant must satisfy Turkish corporate and sector-specific requirements, including the applicable company form, registered-share rules where relevant, capital, disclosure, technical and financial capability, and any approval required for later ownership changes.
Does every renewable project qualify for YEKDEM?
No. Eligibility depends on the statutory framework, YEK certificate, technology, commissioning date, application and market requirements, and the Presidential decision in force. Tariff, duration and indexation should be verified for the specific facility and financial-close date.
Is unlicensed generation free from regulation?
No. It is exempt from the generation license and, in relevant cases, the company-formation requirement, but remains subject to an eligible regulatory category, connection approval, project and acceptance procedures, metering, settlement, system-use and surplus-energy rules.
Can a foreign investor acquire an operating power plant by purchasing its shares?
Yes, but the transaction must be reviewed under the Electricity Market Law, Licensing Regulation, competition law and the project's financing documents. EPDK approval or notification may be required, and the acquisition agreement should not permit closing before mandatory conditions are satisfied.
May a Turkish corporate PPA be priced in foreign currency?
The answer is transaction-specific. The residence of the parties, contract classification, payment mechanics and current exceptions under Decree No. 32 and Communique No. 2008-32/34 must be analyzed. Foreign currency should never be assumed to be valid merely because the project has foreign investment or financing.
What is the most important first step in Turkish energy due diligence?
Confirm that the project described commercially is the same project authorized legally. Match the company, license or application, capacity, coordinates, grid connection, land, environmental decision, construction status and revenue assumptions before valuing the asset.
How can an investor challenge an EPDK decision?
EPDK decisions are administrative acts and may be challenged before the competent administrative court within the applicable filing period. The exact notification date, standing, requested interim relief, technical record and statutory basis should be reviewed immediately because procedural deadlines are strict.
Conclusion
Turkey's energy sector offers substantial opportunity, but the value of an investment depends on regulatory coherence. The project company, license, grid capacity, site, environmental pathway, construction contracts, revenue structure and financing must describe the same project and allocate the same risks. A weakness in any one layer can delay commissioning or undermine bankability.
Foreign investors should treat regulatory diligence as a continuing governance function. EPDK rules, Presidential decisions, market procedures and technical standards evolve throughout a project life measured in decades. Transaction documents should allocate change in law, require timely compliance information and preserve exit flexibility without assuming that regulatory approvals are automatic.
Experienced Turkish counsel adds the most value by connecting public-law authorizations with corporate, contractual and financing decisions before capital is committed. That integrated approach is the practical foundation for a defensible and financeable energy investment in Turkey.
Bibliography and Official References
Legislation and Official Regulatory Materials
Electricity Market Law No. 6446, consolidated official text. Available at: https://www.mevzuat.gov.tr/MevzuatMetin/1.5.6446.pdf [accessed 23 September 2026].
Law No. 5346 on the Use of Renewable Energy Resources for Electricity Generation, consolidated official text. Available at: https://www.mevzuat.gov.tr/MevzuatMetin/1.5.5346.pdf [accessed 23 September 2026].
Foreign Direct Investment Law No. 4875, consolidated official text. Available at: https://www.mevzuat.gov.tr/MevzuatMetin/1.5.4875.pdf [accessed 23 September 2026].
Natural Gas Market Law No. 4646, consolidated official text. Available at: https://www.mevzuat.gov.tr/MevzuatMetin/1.5.4646.pdf [accessed 23 September 2026].
Petroleum Market Law No. 5015, consolidated official text. Available at: https://www.mevzuat.gov.tr/MevzuatMetin/1.5.5015.pdf [accessed 23 September 2026].
Liquefied Petroleum Gases Market Law No. 5307, consolidated official text. Available at: https://www.mevzuat.gov.tr/MevzuatMetin/1.5.5307.pdf [accessed 23 September 2026].
Turkish Petroleum Law No. 6491, consolidated official text. Available at: https://www.mevzuat.gov.tr/MevzuatMetin/1.5.6491.pdf [accessed 23 September 2026].
EPDK, Electricity Market Legislation List. Available at: https://epdk.gov.tr/Detay/Icerik/23-2-3/mevzuat [accessed 23 September 2026].
EPDK, Electricity Market Licensing Application Procedures. Available at: https://epdk.gov.tr/Detay/Icerik/21-3-3/lisans-islemleri-basvuru-prosedurleri [accessed 23 September 2026].
EPDK, Unlicensed Electricity Generation Materials. Available at: https://epdk.gov.tr/Detay/Icerik/3-0-0-1160/elektrik-piyasasinda-lisanssiz-elektrik-uretimi- [accessed 23 September 2026].
Ministry of Energy and Natural Resources, Licensed Electricity Generation. Available at: https://enerji.gov.tr/eigm-yenilebilir-enerji-uretim-faaliyetleri-lisansli-elektrik-uretimi [accessed 23 September 2026].
Ministry of Energy and Natural Resources, Unlicensed Electricity Generation. Available at: https://enerji.gov.tr/eigm-yenilenebilir-enerji-uretim-faaliyetleri-lisassiz-elektrik-uretimi [accessed 23 September 2026].
Ministry of Energy and Natural Resources, Domestic Component Support. Available at: https://enerji.gov.tr/eigm-yerli-aksam-destekleri [accessed 23 September 2026].
Presidential Decision No. 7189, Official Gazette No. 32177, 1 May 2023. Available at: https://www.resmigazete.gov.tr/eskiler/2023/05/20230501-4.pdf [accessed 23 September 2026].
Regulation Amending the Unlicensed Electricity Generation Regulation, Official Gazette, 14 May 2024. Available at: https://www.resmigazete.gov.tr/eskiler/2024/05/20240514-4.htm [accessed 23 September 2026].
Regulation Amending the Electricity Market Storage Activities Regulation, Official Gazette, 29 December 2025. Available at: https://www.resmigazete.gov.tr/eskiler/2025/12/20251229-4.htm [accessed 23 September 2026].
Ministry of Treasury and Finance, Communique No. 2008-32/34, consolidated official text. Available at: https://ms.hmb.gov.tr/uploads/2025/07/Turk-Parasi-Kiymetini-Koruma-Hakkinda-32-Sayili-Karara-Iliskin-Teblig-d2e065a8155e81ed.pdf [accessed 23 September 2026].
Selected Higher Court Decisions
Constitutional Court, E. 2013/65, K. 2014/93, 22 May 2014. Available at: https://www.anayasa.gov.tr/tr/mahkeme-gundemi/genel-kurul/22-mayis-2014-genel-kurul-gundemi-ve-sonuclari/ [accessed 23 September 2026].
Council of State, 13th Chamber, E. 2024/503, K. 2024/3471, 23 September 2024. Available at: https://karararama.danistay.gov.tr/getDokuman?arananKelime=,2024/503+E.,+2024/3471+K.&id=1098587800 [accessed 23 September 2026].
Council of State, 13th Chamber, E. 2021/2981, K. 2024/5448, 12 December 2024. Available at: https://karararama.danistay.gov.tr/getDokuman?arananKelime=resim&id=1191957900 [accessed 23 September 2026].
Selected Legal Books
Gozler, Kemal. Idare Hukuku. 3rd ed. Bursa: Ekin, 2019.
Tan, Turgut. Idari Islemin Geri Alinmasi. Ankara: Ankara University Faculty of Political Sciences Publications, 1970.
Ulusoy, Ali D. Yen
Footnotes
1. Electricity Market Law No. 6446, particularly arts. 4 to 7 and 14, official consolidated text, Republic of Turkiye Legislation Information System.
2. Natural Gas Market Law No. 4646; Petroleum Market Law No. 5015; Liquefied Petroleum Gases Market Law No. 5307; EPDK official market legislation pages.
3. Foreign Direct Investment Law No. 4875, art. 3. Foreign investors receive equal treatment, subject to sector-specific licensing, competition, national security and other mandatory rules.
4. EPDK, Electricity Market Licensing Application Procedures, current official guidance. Private-law applicants must generally be incorporated as a joint stock company or limited liability company under the Turkish Commercial Code.
5. Electricity Market Licensing Regulation, Official Gazette No. 28809, 2 November 2013, as amended; EPDK, Pre-License and Generation License Process.
6. Electricity Market Law No. 6446, arts. 5 and 6; Electricity Market Licensing Regulation provisions on pre-license share transfers, mergers, demergers and license amendments.
7. Law No. 5346 on the Use of Renewable Energy Resources for Electricity Generation, arts. 6 and 6/B; Presidential Decision No. 7189, Official Gazette No. 32177, 1 May 2023.
8. Republic of Turkiye Ministry of Energy and Natural Resources, Licensed Electricity Generation. The official page confirms YEKDEM treatment for eligible YEK-certified facilities entering operation from 1 July 2021 through 31 December 2030.
9. Regulation on Domestic Manufacture of Components Used in Facilities Generating Electricity from Renewable Energy Resources, Official Gazette No. 31494, 28 May 2021; Ministry of Energy and Natural Resources, Domestic Component Support.
10. Republic of Turkiye Ministry of Energy and Natural Resources, Unlicensed Electricity Generation; Electricity Market Law No. 6446, art. 14; Electricity Market Unlicensed Electricity Generation Regulation.
11. Regulation Amending the Unlicensed Electricity Generation Regulation, Official Gazette, 14 May 2024. The amendment addresses completion periods and the consequences of failing to execute the system-use agreement after commissioning.
12. Regulation Amending the Electricity Market Storage Activities Regulation, Official Gazette, 29 December 2025, permitting storage facilities in specified unlicensed generation projects subject to the regulatory conditions.
13. Electricity Market Aggregation Activities Regulation and related market rules; Electricity Market Measurement Systems Regulation, Official Gazette, 28 December 2023; EPDK official electricity legislation list.
14. Natural Gas Market Law No. 4646 and Natural Gas Market Licensing Regulation; EPDK, Natural Gas Market Legislation List.
15. Petroleum Market Law No. 5015 and Petroleum Market Licensing Regulation; EPDK, Petroleum Market Legislation List.
16. Turkish Petroleum Law No. 6491, which governs upstream petroleum exploration and production, together with the implementing regulation and Ministry procedures.
17. Environmental Law No. 2872; Environmental Impact Assessment Regulation, Official Gazette No. 31907, 29 July 2022, as amended. Project-specific screening and permitting must be confirmed against the current annexes.
18. Communique No. 2008-32/34 on Decree No. 32 concerning the Protection of the Value of Turkish Currency, art. 8, as amended; Ministry of Treasury and Finance official consolidated text and guidance.
19. Constitutional Court, E. 2013/65, K. 2014/93, 22 May 2014. The Court reviewed multiple provisions of Electricity Market Law No. 6446 and annulled specified transitional provisions while rejecting other challenges.
20. Council of State, 13th Chamber, E. 2024/503, K. 2024/3471, 23 September 2024. Official Council of State Case Law Database.
21. Council of State, 13th Chamber, E. 2021/2981, K. 2024/5448, 12 December 2024. Official Council of State Case Law Database.
22. EPDK Board Decision No. 14051 dated 18 December 2025, published in Official Gazette No. 33113 on 20 December 2025, concerning electricity pre-license and license fees applicable in 2026.
23. EPDK, Electricity Market Legislation List, current official compilation, including licensing, balancing and settlement, storage, aggregation, measurement and distribution rules.
24. EPDK licensing guidance states that equivalent documents are requested where shareholders are foreign companies or foreign nationals. Foreign documents may also require notarization, apostille or consular legalization and certified Turkish translation.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
