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I. INTRODUCTION
The amendments introduced by the Regulation on the Amendment of the Charging Service Regulation (the “Regulation”), published in the Official Gazette dated 23 March 2026 and numbered 33202, demonstrate that the electric vehicle ecosystem in Türkiye has evolved from merely a growing market into a more sophisticated regulatory domain. While the Regulation deepens the existing framework across various areas ranging from mobile charging solutions to data security standards, from price transparency to interoperability within the market, it also renders the obligations of market players clearer and more measurable. In this respect, the amendments do not merely constitute a technical update; they also signal a transition to a new phase in the charging services market shaped by competition, transparency, and user-centricity.
II. FUNDAMENTAL PRINCIPLES
An examination of the Regulation indicates that, particularly from the users’ perspective, the pricing structure has been significantly simplified, as charging service fees are now to be applied solely in TL/kWh and no additional fees may be charged under any other name. Furthermore, mandating card and contactless payment options at certain charging units and explicitly prohibiting additional charges for such methods enhance accessibility and make the process more practical for users. In addition, it is understood that the concept of a charging network has been expanded to include mobile charging stations and interoperability mechanisms, that data security obligations are being aligned with international standards, and that service quality is aimed to be improved through regulations enabling users to access real-time information regarding price, availability, and service conditions. The key amendments are summarized below under separate headings:
- Simplified Pricing: Single Fee, Clear Rules
With the amendments, the pricing structure of charging services has been significantly simplified. Pricing will now be based solely on TL/kWh, and no additional fees—such as connection fees, transaction initiation fees, or equipment usage fees—may be charged under any name beyond the amount calculated based on the charging service price. This constitutes an important step towards ensuring that users can clearly understand what they are paying for. In addition, transparency has been strengthened by requiring prices to be shared in real time through digital channels and at charging stations.
Operators are also allowed to apply discounted pricing based on the time of day and the location of the station. However, an important rule protects users: even if prices change after charging has started, the user will pay according to the price applicable at the time the transaction began. Since such discounted prices must be clearly communicated to users and notified to the Energy Market Regulatory Authority (“Authority”), the system is intended to operate in a transparent and controllable manner.
- Introduction of Congestion Management at Charging Stations
An important step has been taken towards more efficient management of congestion at charging stations. In DC charging units, once a vehicle’s battery level reaches 85% or above, the charging service may be terminated, provided that the user has been informed in advance. This mechanism aims to improve the efficiency of station usage and enable more users to access the service during peak hours. However, it remains unclear how such notifications will be made and to what extent users will be able to anticipate this process. This issue will be particularly significant for users planning long-distance travel.
- Card and Contactless Payment Options Clearly Regulated
At newly added charging stations on highways under the responsibility of the General Directorate of Highways, at least one of the DC charging units with a capacity of 50 kW or above must provide card or contactless payment options. This requirement will come into force as of 1 July 2026. Moreover, no additional fees, commissions, or price differences may be charged to users for these payment methods. This regulation is expected to facilitate access to charging services and make the process more practical for users.
- Expansion of the Charging Network Definition: A Growing System
The Regulation no longer considers charging services as limited to physical stations. Structures such as mobile charging stations, smart charging systems, and interoperability between different networks (roaming) have been explicitly included within the system. Accordingly, the charging network is now approached as a more holistic structure encompassing both software and hardware. This indicates that the sector has expanded both technically and commercially.
In this context, particular attention should be drawn to the contractual structure of roaming arrangements introduced by the Regulation. Indeed, this aspect entails legal and operational considerations that must be evaluated both from the perspective of prospective roaming “contracting parties” holding a charging network operator license and from the perspective of users.
Within the Regulation, roaming agreements are defined as agreements enabling charging network operators to directly provide services to each other’s users and covering data and payment flows. Furthermore, it is stipulated that contracting parties holding a charging network operator license must notify the Authority within 30 days following the execution of such roaming agreements. In addition, the Authority is authorized to determine the procedures and principles, as well as the necessary protocols, regarding activities carried out under roaming agreements.
This approach demonstrates that, on the one hand, the regulatory authority may guide the general framework in the forthcoming period; however, in the absence of any protocol or secondary legislation issued by the Authority at this stage, the current practice is expected to be shaped largely within the framework of contractual freedom between the parties in other words, a structure in which the framework is effectively filled in by the parties themselves. Nevertheless, it should also be taken into consideration that, should mandatory provisions arise through future regulations and protocols to be issued by the Authority, existing agreements will need to be reviewed and adapted accordingly.
In this context, in roaming relationships, it is essential that matters such as data sharing, management of payment and collection processes, revenue sharing, service continuity and quality standards, and allocation of responsibilities between the parties are clearly and comprehensively regulated within the agreements. In particular, the structuring of the collection mechanism (including which party will collect payment from the user and how reconciliation and transfer processes between the parties will operate) stands out as a critical area in terms of both managing commercial risks and ensuring operational continuity.
From the user (consumer) perspective, it is also necessary for the roaming structure to be transparent and predictable. Regardless of which network the user receives the service from, clear information should be provided regarding pricing, payment, and service conditions; it should be clarified who the counterparty is in case of disruptions arising from services provided across different operators; and liability in potential disputes should be clearly determined. Therefore, roaming agreements should be considered not only as instruments governing commercial relations between parties but also as structures that directly affect user experience and trust.
- Clarification of Operator’s Authorities and Notification and Application Processes for Charging Activities
It is observed that the framework regarding the authorities and obligations of charging network operators has also been further clarified. Activities such as the establishment and operation of a charging network, the operation of mobile charging stations, the contractual relationships established with users, and the execution of practices related to invoicing and the collection of fees within the scope of charging services are regulated under the license regime. In addition, it appears that notification and application processes concerning the integration of new stations into the network, the transfer of existing stations, and mobile charging activities have been simplified and rendered more traceable. Accordingly, in the event of the transfer of charging stations from one charging network operator to another, both the transferring and the transferee operators are required to notify the Authority electronically, and following the approval of such notifications by the Authority, a further notification must be made to the relevant charging network operator. Within this process, it is stipulated that the certificate of favorable opinion issued in the name of the transferring operator shall be revoked and reissued in the name of the transferee operator.
- Strengthening of User-Oriented Service Approach; Introduction of Certification Requirement for Software Systems in Information Security
With the amendments, significant obligations have also been introduced in the areas of user experience and data security. Accordingly, charging network operators are required to establish communication channels through which user complaints can be submitted and tracked, and to set up or procure a call center certified under ISO 18295 that will operate on a 24/7 uninterrupted basis. In addition, it has been made mandatory to provide real-time information regarding the status and availability of stations and sockets, as well as pricing information, and to ensure that user requests are resolved within specified time periods. A transition period of six months has been granted to existing license holders for the implementation of these requirements.
On the other hand, the bar has been significantly raised in terms of data security. While it has become mandatory to ensure the protection of data obtained within the scope of charging services, to prevent unauthorized access, and to operate IT infrastructure in compliance with international standards, it is explicitly regulated that systems must comply with the TS ISO/IEC 27001 standard. Within this scope, ensuring elements such as authentication, access control, and secure communication becomes a fundamental obligation for operators. A transition period of one year has been granted to existing license holders for the fulfillment of these obligations.
III. CONCLUSION
Overall, the amendments aim to establish a more transparent, predictable, and user-oriented structure in the charging services market. The regulations introduced across various areas from pricing and payment processes to data security and operational obligations not only require technical compliance from market players but also bring about a more systematic and standardized approach to business practices.
In particular, the simplification of the pricing structure, the expansion of direct payment options, and the enhancement of the level of information provided to users stand out as significant developments directly affecting user experience. However, certain areas such as congestion management will need to be closely monitored in the coming period in terms of how they will be implemented and whether uniformity can be achieved across the market.
Furthermore, with the expansion of the definition of the charging network, it is understood that the contractual relationships to be established within the scope of interoperability (roaming) will play a critical role in shaping the practice, particularly in terms of data sharing, collection mechanisms, allocation of responsibilities, and service conditions reflected to users. In this respect, the proper and sustainable structuring of roaming arrangements will directly affect not only the balance between market players but also user trust and service quality.
In this framework, it would be appropriate to consider these amendments not merely as technical updates to the existing structure, but as an important component of the transition towards a more mature, competitive, and user-centered charging services market.
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