Turkey: Significant Changes in Renewable Energy and Electricity Law in 2025

1) Electricity Market Licensing Regulation – 2025-12-29 (Official Gazette No. 33122)

1.1. Expansion of the Definition of Floating Photovoltaic Systems

With the legal amendment, the definition of floating photovoltaic systems (Floating PV systems) has been redefined. Subject to certain, explicitly regulated exceptions, solar-based generation facilities erected on the surface of seas, reservoirs, natural lakes, and artificial lakes have now been expressly included within the scope of this definition.

1.2. Clarification of the Deadline Regime for Transfers of Licensed Generation Facilities

It has been explicitly stipulated that the approval granted by the Energy Market Regulatory Authority (EMRA) for transfer, sale, or lease transactions remains effective only if the transaction in question is actually completed within the period specified by the authority. If the transaction is not completed within this period, the approval has no legal effect, and the transfer process cannot be continued without a new decision from EMRA.

In this context, a special deadline regime was introduced for licensed generation facilities already in operation or partially operated. Accordingly, transfers must be completed within a period to be determined by EMRA from the date of approval; this period may not be shorter than six months. If not completed on time, the approval loses its validity.

1.3. Clarification of the Time and Legal Framework for YEKA Projects

The amendments harmonized the deadlines and procedures for YEKA (Renewable Energy Resource Area) projects with the general rules for electricity generation licenses.
If the YEKA contract is terminated by the competent ministry and this circumstance is notified to EMRA, the preliminary license and the generation license issued for the project in question may be revoked.

Furthermore, the extension of the preliminary license period for YEKA projects is no longer structured as an automatic right but has been made dependent on the positive vote of the Ministry.

1.4. Update of Practice for Overlaps Between Licensed Areas and Unlicensed Applications

Under the previous regulation, submitting an application for unlicensed generation for areas for which a license or preliminary license exists was impermissible. However, the new regulation clarified the procedure for partial or complete area overlaps.

In such cases, it is now stipulated that the application will not be rejected but can be renewed under certain conditions and the procedure continued within the framework of the regulations for unlicensed generation.

1.5. Introduction of a Cap on Feed-in Under Supply and Aggregator Licenses

The new regulation explicitly stipulates that the amount of electricity fed into the grid by facilities operating under a supply or aggregator license is limited to the installed capacity of the facility.

If this limit is exceeded, the excess energy fed in will not be included in the balancing settlement and will remain in the system without remuneration.

2) Balancing and Settlement Regulation – Package of 2025-12-29

2.1. New Requirement for Including Free Consumers in Portfolios

The amendment stipulated that companies with a generation license are obliged to have at least one of their generation facilities or units registered in the system as a balancing-relevant feed-in/withdrawal unit (UEVÇB).

2.2. Impact of the Aggregator License on the Structure of Balancing Responsibility Groups (DSG)

The regulations concerning aggregator activities have been clarified. Accordingly, the acquisition of an aggregator license or the expansion of an existing license to include aggregator activities has direct implications for membership in a Balancing Responsibility Group (DSG).
If the company in question is a member of a DSG, the membership ends; if it is a contracting party to a DSG, the corresponding DSG structure ceases to exist.

Furthermore, it is impermissible for the same generation or consumption facility to be included in the portfolios of multiple aggregators. Facilities managed in special categories for separate settlement may also not be assigned to any aggregator portfolio.

2.3. Introduction of a Daily Obligation to Report Available Capacity (Art. 69/A)

With the new regulation, market participants are obliged to report the technically maximum feed-in or withdrawal capacity to TEİAŞ daily by 3:30 PM. In case of incomplete or omitted reporting, systematic underestimation of capacity citing disruptions or maintenance, or incorrect declarations or actions in the balancing energy market, TEİAŞ will forward the matter to EMRA, and administrative measures may be taken under the Electricity Market Law.

3) Storage Regulation – Including Unlicensed Storage

3.1. Definition of the Scope of Storage for Unlicensed Generation Facilities

Certain unlicensed generation facilities were permitted to establish energy storage units.
If energy is fed into the grid from these storage units, no remuneration will be provided for it; the fed-in energy will be treated as a gratuitous contribution within the YEKDEM system. In certain cases, this also applies to all excess energy fed in.

3.2. Clear Feed-in Limits for Storage-Integrated Generation and Electricity Storage Facilities

It has been explicitly stipulated that the energy fed into the grid from storage-integrated generation facilities and integrated electricity storage facilities is limited to the provisional or final accepted electrical connection capacity.

If this limit is exceeded, the excess energy will not be included in the balancing settlement and is considered to be utilized gratuitously within the system.

4) YEKDEM Regulation – Rules for Energy and YEK Remuneration Calculation After Expiry of YEKDEM Participation for Storage Facilities

The amendments clarified that energy generated and stored within the framework of YEKDEM (short for the Renewable Energy Sources Support Mechanism) that is fed into the grid after the facility’s exit from the YEKDEM system will not be included in the feed-in quantity relevant for YEK settlement. At the same time, the calculation method for YEK remuneration was updated, and among other things, it was stipulated that YEKDEM revenues are included in the calculation and production above the reported KGÜP (short for the final daily generation plan) on certain days is excluded from the YEK calculation.

5) Miscellaneous: Smart Meter Rollout Schedule

A decision made by EMRA at the end of 2025 established the principles for the gradual replacement of conventional electricity meters with smart meters. Implementation begins on March 1, 2026. Distribution network operators are obliged to install Smart Meter PRO and Smart Meter EKO with limited functionality.

6) Regulation on Unlicensed Electricity Generation – 2025-11-25 (Official Gazette No. 33088)

The amendment of November 25, 2025, aims to make the application and technical review procedures for unlicensed generation clearer and more uniform. After a positive application review, technical data must be submitted to the General Directorate of Energy Affairs (EİGM) via the Monitoring and Tracking System of the Renewable Energy Sources Support Mechanism (YEKDİS); the technical evaluation must be completed within clearly defined deadlines.

Particularly for geothermal and biomass projects, a centralized technical review is foreseen, thereby strengthening the uniformity of application. The regulation shows that for unlicensed projects, the technical correctness of application documents, complete data submission, and stringent deadline management have significantly gained importance.

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