Turkey's Climate Law: Emission Permits and Fines Explained

Turkey entered a new era of environmental regulation when the Climate Law (İklim Kanunu, Law No. 7552) came into force in July 2025. For the first time, the country has a single statute that sets binding greenhouse gas reduction targets, establishes an Emission Trading System, and backs it all with real administrative fines. If your company operates in Turkey — or you are thinking of investing in an industrial or energy project near Antalya — understanding this framework matters now, not later.

What the Climate Law Sets Out to Do

The law's goal is to fight climate change in line with Turkey's vision of green growth and a net-zero emission target. It covers the full lifecycle of regulatory action: reducing greenhouse gas emissions, adapting to climate change impacts, and creating the institutional tools to achieve both.

A dedicated Climate Change Authority (İklim Değişikliği Başkanlığı) sits at the centre of enforcement. This body issues permits, manages the emission trading system, oversees inspections, and hands down administrative fines. Businesses with emission-related obligations will interact with this Authority for every step of the compliance process.

The law's scope is broad — it touches energy production, heavy industry, and any other activities that cause direct greenhouse gas emissions as defined in the implementing regulations. Foreign-owned companies are treated no differently from domestic ones. Compliance is mandatory regardless of ownership structure or where the parent company is headquartered.

The Emission Trading System — What Your Business Needs

At the heart of the law is Turkey's Emission Trading System (ETS — Emisyon Ticaret Sistemi). If your facility falls within the regulated sector categories, you cannot legally operate without first obtaining a greenhouse gas emission permit (sera gazı emisyon izni) from the Climate Change Authority.

Once permitted, your obligations run year-round. You must track your facility's emissions continuously, have them independently verified, and submit a verified annual emission report. On top of that, you must deliver an equivalent number of emission allowances (tahsisat) each year — essentially certificates representing your entitlement to emit a measured quantity of greenhouse gases. The Authority distributes allowances according to a national allocation plan published in the Official Gazette.

If circumstances change — a modification to your facility, a change in ownership, or a halt in operations — the permit must be updated or the Authority notified promptly. An emission permit can be updated or revoked when the terms on which it was granted no longer hold.

Administrative Fines — What the Law Actually Threatens

The penalty structure in Article 14 of the Climate Law is specific and can be severe.

Failure to submit a verified emission report on time brings a fine ranging from 500,000 to 5,000,000 Turkish lira. For businesses already inside the ETS, the same fine is doubled.

Operating without a valid emission permit — or continuing to operate after your permit has been revoked — triggers a fine calculated per tonne of CO₂ equivalent emitted. Where the business already has a verified emission report on file, the rate is 5 Turkish lira per tonne based on the highest emission figure reported in the previous five years. Where no verified report exists, the fine ranges from 1,000,000 to 10,000,000 Turkish lira.

Failing to deliver the required allowances on time carries a penalty per missing allowance equal to twice the higher of the weighted average allowance price on the primary or secondary market for the last quarter of the year in question. Market prices fluctuate, so this exposure can be substantial.

Beyond ETS obligations, the law sets separate fines for handling ozone-depleting substances and fluorinated greenhouse gases without the required authorisations — starting at 120,000 lira for labelling violations and reaching 2,500,000 lira for unlicensed import or trade. Providing false or misleading information to the Authority carries a 170,000 lira fine.

The law caps any single fine at 50,000,000 lira. Repeat violations attract multipliers — the first repetition doubles the base fine, subsequent repetitions triple it. All amounts are adjusted upward annually using the official inflation revaluation rate.

Grace Periods and When the Ministry Can Stop You

Before imposing a fine, the Ministry of Environment, Urbanisation and Climate Change can grant a one-time grace period of up to one year to fix a violation. That grace does not pause fines — penalties and the correction clock run simultaneously. If the violation remains uncorrected when the period expires, the Ministry can suspend the activity partially or entirely until compliance is restored.

Long-running non-compliance on allowance delivery has its own track: three consecutive years in which a business delivers fewer than 80% of its required allowances results in permit cancellation and a 3-to-6-month ban on receiving a new permit.

Challenging a Fine or Permit Decision

Administrative sanctions under the Climate Law are contested in the administrative courts (idari yargı). The opposing party is the Climate Change Authority. You can seek cancellation of a fine or of a permit revocation decision through this route.

One important practical point: filing a case does not automatically suspend payment of the fine. The fine remains collectible while your case is pending unless you also apply for a stay of execution (yürütmeyi durdurma). Understanding the administrative court procedure for foreigners in Turkey is therefore essential before committing to litigation.

The collection procedure follows the Misdemeanours Law (Kabahatler Kanunu), which gives additional procedural rights to the person fined, including the right to formal notification before enforcement steps are taken. You may also find our guide on objecting to fines in Turkey useful for procedural context.

Frequently Asked Questions

Q: Does the Climate Law apply to a foreign-owned company in Antalya?

Yes. The law applies to any business that conducts regulated activities in Turkey, irrespective of the nationality of the owner. If your facility causes direct greenhouse gas emissions covered by the implementing regulation, you need an emission permit.

Q: What is a greenhouse gas emission permit and how do you get one?

It is a formal authorisation from the Climate Change Authority allowing your facility to operate. You apply to the Authority with technical documentation about your facility. Operating without this permit is a serious violation with significant financial consequences.

Q: Can an administrative fine be contested?

Yes, through an administrative court action against the Climate Change Authority. The time limit for bringing this action follows the general rules of Turkish administrative procedure law. Filing a case does not suspend collection — a separate application for a stay of execution is needed for that.

Q: Are the fine amounts fixed permanently?

No. The fine thresholds in the law are adjusted annually using the official inflation revaluation rate. The updated amounts for each year are announced through a communiqué published in the Official Gazette.

Q: What triggers permit cancellation?

The most common pathway is three consecutive years of delivering fewer than 80% of the required allowances. After cancellation, a new permit cannot be issued for a period ranging from three to six months.

How Mona Hukuk Can Help

Mona Hukuk advises businesses operating in Turkey — including foreign investors with industrial or energy assets in and around Antalya — on regulatory compliance, emission permit processes, and challenging administrative sanctions under the new Climate Law.

Contact us at info@monahukuk.com or call +90 (242) 606 14 32 to schedule a consultation in Antalya.