With the Climate Law No. 7512 ("Law"), published in the Official Gazette dated 9 July 2025 and numbered 32545, Turkey's nationally determined contributions under the Paris Agreement have been granted a domestic legal basis for the first time and a legislative framework has been established on key areas such as carbon regulations, emissions trading system, and climate finance.
Prepared in line with the vision of green growth and the net zero emissions target, the Law introduces numerous significant innovations in the fight against climate change, along with important obligations for both the public and private sectors.
1. General Overview
The long-awaited Law addressing Turkey's fight against climate change covers public institutions and organizations as well as natural and legal persons. This new Law brings a systematic structure to climate policies by regulating a wide range of topics including activities related to combating and adapting to climate change, planning and implementation tools, the Emissions Trading System, voluntary carbon markets and offsetting, use of revenues and supports, and sanctions.
Key provisions introduced by the Law are explained in detail under the following headings.
2. Activities to Combat Climate Change
Climate change efforts are addressed under two main pillars: (i) the reduction of greenhouse gas emissions, and (ii) adaptation to climate change. These efforts will be monitored annually by the Climate Change Presidency ("Presidency"). Accordingly, the Nationally Determined Contribution, the net zero emissions target, and the strategy documents and action plans prepared by the Presidency will form the basis for both emission reduction and adaptation activities.
In terms of emission reduction, public institutions and organizations will be required to revise their plans in line with these targets, and to increase efficiency in energy, water, and raw material usage, promote the use of renewable energy, and implement zero waste systems. Measures are also envisaged to protect and expand carbon sink areas.
As for adaptation to climate change, public institutions and organizations will be responsible for actions such as managing water resources, preserving ecosystems, promoting nature-based solutions in agriculture, and implementing early warning systems to reduce disaster risks.
3. Planning and Implementation Tools
The Law introduces planning and implementation tools to ensure that public institutions and organizations can effectively carry out climate change mitigation and adaptation efforts.
In terms of planning tools, strategy, plan, and policy documents prepared by public institutions and organizations will be based on the strategy and action plans published by the Presidency.
At the national level, strategy and action plans will be periodically prepared, implemented, monitored, and updated. At the local level, Climate Change Coordination Boards will be established in each province under the leadership of the governor.
On the other hand, implementation tools are categorized under three main groups: financial tools, technological tools, and capacity-building tools.
Under the Law, it is regulated that various incentives, support mechanisms, and insurance instruments will be developed within the scope of financial tools. Additionally, a Turkish Green Taxonomy will be established, and a Border Carbon Adjustment Mechanism may be implemented to address the embedded greenhouse gas emissions of imported goods.
Moreover, in terms of capacity-building tools, the Law foresees coordinated efforts with the Ministry of National Education (MEB) and the Council of Higher Education (YÖK) to foster a green workforce.
4. Emissions Trading System
The Law introduces the establishment of an Emissions Trading System ("ETS") and designates the Energy Markets Operation Joint Stock Company (Enerji Piyasaları İşletme Anonim Şirketi) as the operator of the ETS market.
Accordingly, businesses that cause greenhouse gas emissions will be required to obtain an emissions permit from the Presidency in order to continue their operations. Under the national allocation plan, annual allowances will be granted to such businesses. In cases where the allocated allowances are not delivered, additional obligations and sanctions will apply.
Furthermore, the Carbon Market Board ("Board"), chaired by the Ministry of Environment, Urbanization and Climate Change ("Ministry"), will be authorized to approve the National Allocation Plan to be published in the Official Gazette, determine the distribution of free allowances in the ETS market, decide on the quantity of allowances to be offered for sale on the primary market, and determine the percentage of offsetting allowed within the ETS. The Board will also be responsible for defining ETS-related strategies, limitations, and the main policy framework for imports and exports. Key actors such as the market operator Energy Markets Operation Joint Stock Company (Enerji Piyasaları İşletme Anonim Şirketi) and the Central Counterparty Institution will be responsible for the financial and technical operation of the system.
On the other hand, part of the ETS obligations may be fulfilled through carbon credits. A national carbon crediting and offsetting system will be established, and emission reduction projects will be supported through this system. Project owners falling within this scope will be required to register their projects with the system.
5. Transition Period and Key Dates
The transition phase and key implementation deadlines under the Law are outlined as follows:
- A pilot phase will be implemented prior to the full enforcement of the ETS. During this pilot period, the administrative fines stipulated under the Law (as detailed below) will be reduced by 80%.
- Businesses falling within the scope of the ETS must obtain a greenhouse gas emission permit by 08.07.2028. These businesses will be deemed to have obtained such permits once, within the scope of the Law, until that date. This deadline may be extended by the Presidency until 08.07.2030, upon the decision of the Carbon Market Board.
- Legislative and planning instruments related to climate change mitigation efforts must be prepared by 31.12.2027 at the latest. This deadline may be extended until 31.12.2028 by a Presidential decision.
- Local climate change action plans must also be prepared by 31.12.2027, with the possibility of extension to 31.12.2028 by decision of the Ministry.
6. Sanctions and Enforcement Mechanisms
The administrative fines stipulated under the Law range from TRY 120,000 to TRY 50,000,000, depending on the nature of the violation.
Monetary penalties are foreseen for non-compliance with greenhouse gas emission monitoring obligations, failure to surrender allowances under the ETS, or conducting activities without the required emission permit. Sector-specific fines are also introduced in cases of non-compliance with the applicable procedures related to fluorinated greenhouse gases and ozone-depleting substances. Similarly, companies that fail to meet their allowance surrender obligations under the ETS for three consecutive years may have their permits revoked.
In addition to monetary fines, the Law provides for various administrative measures such as suspension of operations, restricted access to allowances, and denial of emission permits. Furthermore, criminal liability under the Turkish Penal Code or other applicable legislation is preserved in cases where the conduct constitutes a criminal offense.
The enforcement and supervision of sanctions will primarily be carried out by the Presidency, and in cases where on-site inspections are deemed necessary, regional branches of the Ministry may also be involved in the process.
The full text of the Law is available here.
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.
