Türkiye's First Climate Law Enters Into Force

A. INTRODUCTION

Following the ratification of the Paris Agreement by the Grand National Assembly of Türkiye in 2021 and the subsequent announcement of the country's net-zero emissions target for 2053, the legislative groundwork for a national climate framework began in 2022. As a result, the Climate Law No. 7552 ("Law") was published in the Official Gazette dated 9 July 2025 and numbered 32951, entering into force on the same date.

This Law serves as a comprehensive legal framework designed in line with Türkiye's vision of green growth and net-zero emissions. It aims to combat climate change and promote adaptation by introducing emission reduction obligations, establishing carbon markets, imposing sector-specific requirements, and providing a legal basis for national strategies against climate-related risks. Significantly, the Law also paves the way for the establishment of the Emissions Trading System as an institutional mechanism to support sustainable green development.

B. KEY INNOVATIONS INTRODUCED BY THE LAW

The Law adopts the principle of common but differentiated responsibilities and lays down the principles of equity, climate justice, precaution, participation, integration, sustainability, transparency, and a just transition. Under the Law, public institutions and legal and natural people are required to comply with climate-related measures taken in the public interest. When setting the net-zero target, Türkiye's development priorities and specific national circumstances will be taken into account.

1. Net-Zero Emission Target

Greenhouse gas emissions will be reduced in line with the Nationally Determined Contribution ¹, the net-zero target, and the periodic strategies and action plans published or updated by the Climate Change Directorate ("Directorate"). Strategies and action plans will be prepared and implemented both at the national and local levels, with progress being regularly monitored. Local Climate Change Action Plans will also be developed in accordance with the specific priorities and needs of each region.

2. Provincial Climate Change Coordination Boards

A Provincial Climate Change Coordination Board ("Board") will be established in each province under the leadership of the governor, responsible for determining and implementing local strategies and action plans. These Boards will include local representatives of relevant public institutions and local governments. The secretariat services of the Boards will be carried out by the provincial organization of the Ministry of Environment, Urbanization and Climate Change ("Ministry"), and their working procedures will be determined by the Ministry.

3. Climate Change Directorate

The Directorate will monitor annual progress in emission reduction and climate adaptation. It is also authorized to coordinate institutions, set standards, monitor developments, and regulate market-based mechanisms related to carbon pricing. The Emissions Trading System² ("ETS") will be established by the Ministry, which will also be responsible for allocation planning.

4. National Emissions Trading System ("ETS")

The Law envisages the establishment of a national emissions trading system for entities engaged in carbon-emitting activities. Accordingly, a national allocation plan will be prepared, and the distribution of emission allowances will be carried out. This allocation plan shall be published in the Official Gazette.

Within this framework, entities conducting activities that directly result in greenhouse gas emissions to be defined and regulated through secondary legislation must obtain a greenhouse gas emission permit from the Directorate in order to lawfully operate under the ETS.

In addition, entities covered by the ETS will be required to surrender, on an annual basis, an amount of emission allowances corresponding to their verified greenhouse gas emissions.

Operators will be responsible for monitoring their allocated annual emission limits and will be subject to administrative sanctions in the event of non-compliance with their obligations under the ETS.

5. Voluntary Carbon Markets

Under the ETS, it may be permitted to offset a portion of the allocation obligations with an equivalent amount of carbon credits. A portion of the allocation obligations under the ETS may therefore be fulfilled through the use of carbon credits.

A national system will be established to ensure that carbon credits used under the ETS and for voluntary commitments are generated through emission reduction, removal, or the enhancement of carbon sinks. The principles and procedures governing this system shall be determined by the Presidency.

6. Carbon Border Adjustment Mechanism ("CBAM")

A CBAM may be established to manage embedded GHG emissions in goods imported into the Turkish Customs Territory. Reporting obligations, scope, and operational procedures will be set by the Ministry of Trade in collaboration with other relevant ministries.

7. Türkiye's Green Taxonomy

The Directorate will develop national, sectoral, and thematic reports, implement incentive mechanisms for climate-related investments, and establish the Türkiye Green Taxonomy. Under circular economy and zero waste principles, reuse of products, alternative raw materials, and mandatory recycled content ratios will be determined.

8. Other Measures

The Law also introduces the following supplementary mechanisms:

• Cooperation with the Ministry of National Education and the Higher Education Council to enhance the green workforce and integrate climate objectives into educational curricula.
• Protection and sustainable management of forests, wetlands, pastures, and carbon sinks to prevent losses and increase resilience.
• Water management strategies will be developed to address the effects of climate change on water resources.
• Expansion and enhanced protection of marine and terrestrial protected areas.
• Reinforced efforts to combat desertification and erosion.
• Development of nature-based and ecosystem-based adaptation strategies for agriculture, including climate-resilient crop patterns and conservation of biodiversity and natural resources.
• Strengthening risk assessment, monitoring, early warning, and disaster response systems to reduce climate-related losses and damages.

C. SANCTIONS

The Law imposes various administrative sanctions for non-compliance, including administrative fines, suspension of operations, and license revocation:

• Violations related to GHG emission reporting: Enterprises failing to submit verified reports within the deadline face fines between TRY 500,000 and TRY 5,000,000. These penalties are doubled for businesses under the ETS.
• Violations regarding ozone-depleting substances:
• • TRY 2,500,000 for use, import, sale, or placing on the market,
  • TRY 250,000 for maintenance services involving such substances,
  • TRY 120,000 for labeling violations.
• Violations related to fluorinated GHGs (F-gases):
• • An administrative fine of TRY 2,500,000 shall be imposed on persons or entities that use, sell, or place on the market fluorinated greenhouse gases. Additionally, no Hydrofluorocarbon (HFC) Control Certificate shall be issued to such parties for a period ranging from 3 to 6 months.
  • Entities that import HFCs without a quota or in excess of their allocated quota shall be subject to an administrative fine of TRY 1,000,000, and a quota reduction shall be applied for the following year.
  • A fine of TRY 120,000 shall be imposed for non-compliance with labeling requirements related to products, containers, or equipment containing fluorinated gases.
  • Failure to timely fulfill mandatory notification or reporting obligations shall result in an administrative fine of TRY 120,000.
  • Unauthorized intervention in equipment containing fluorinated gases or operating with such gases shall be subject to an administrative fine of TRY 120,000.
• Violations under the ETS:
• • Temporary restrictions will be imposed on allocations for failure to submit verified emission reports. This does not exempt the operator from administrative fines.
  • Operating without a valid emission permit will result in:
  • • TRY 5 per tonne (based on highest verified emissions), or
    • TRY 1,000,000 to TRY 10,000,000 fine (if no report is submitted), based on comparable facility emissions.
  • Failure to submit allocation units on time will result in a fine equal to twice the highest carbon market price recorded in the final quarter of the year per missing unit.
  • Repeated failure to meet at least 80% of allocation obligations for three consecutive years will lead to revocation of emission permits and a 3–6-month application ban.
• Grace Period for Remedying Non-Compliance: In the event that any act in breach of the Law or its secondary legislation is identified, the Ministry may grant, on a one-time basis and for a period not exceeding one year, a grace period for the rectification of such non-compliance.
• Cap on Administrative Fines: The amount of administrative monetary fine to be imposed for each individual violation shall not exceed TRY 50,000,000.
• Pilot Implementation Period: A transitional pilot period will precede the full implementation of the ETS. Its scope, duration, and implementation rules will be set by the Carbon Market Board, considering input from public institutions and civil society. During this period, fines will be imposed at an 80% reduced rate.

D. IMPLEMENTATION

Obligations regarding the preparation and adaptation of legislation and planning tools under the Law must be fulfilled by relevant institutions by 31 December 2027. This deadline may be extended by up to one year by Presidential decree. Similarly, Local Climate Change Action Plans must be prepared by the same date, subject to a one-year extension by the Ministry.

E. CONCLUSION

The Climate Law provides Türkiye with a robust legal framework for achieving its net-zero emission goals while fostering green development. The introduction of the ETS and other regulatory mechanisms imposes new responsibilities on various sectors, encouraging environmental sustainability.

Ultimately, the Law represents a strategic, holistic, and long-term roadmap for Türkiye in its climate transition, aiming to position the country as a more prominent actor in the global climate regime by integrating environmental objectives with national development priorities.

Footnotes

1. Nationally Determined Contribution: A document prepared periodically under the coordination of the Climate Change Directorate, in cooperation with relevant institutions and organizations, in line with international agreements and standards. It outlines Türkiye's greenhouse gas emission reduction targets and climate change adaptation commitments and is submitted to the Secretariat of the United Nations Framework Convention on Climate Change.

2. Emissions Trading System: A national and/or international market-based mechanism that operates on the principle of setting an upper limit on greenhouse gas emissions in line with the net-zero emissions target. It promotes emission reductions through the allocation, trading, and transfer of emission allowances.

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