Key Legislative Developments in Renewable Energy and Electricity in 2025

2025 marked a period of comprehensive regulatory developments in the electricity market and renewable energy market. This legal alert briefly outlines the key aspects of the significant amendments and developments, with particular focus on those introduced towards the end of the year.

1. Key Developments under the Electricity Market Licensing Regulation^[1] (“Regulation”)

According to the regulations published in the Official Gazette dated 29 December 2025 and numbered 33122, comprehensive amendments were introduced to the electricity market and the energy sector, particularly clarifying the procedures applicable to storage and aggregation activities and therefore, eliminating certain regulatory uncertainties.

• 1. Expansion of the Definition of Floating Solar Power Plants: With the recent amendments, solar power plants installed on the water surface of seas, reservoir lakes, artificial lakes and natural lakes, excluding reservoirs used for drinking and domestic water supply, wetlands, and coastal and shoreline areas falling within the scope of the Coastal Law No. 3621, have been included within the definition of a “floating solar power plant”,. Accordingly, the scope of areas where floating solar power plants may be constructed has been expanded.
  2. Invalidity of Transactions in Case of Failure to Transfer the Generation Facility within the Prescribed Period: As per the new amendments in the Regulation, if the transfer, sale or lease transactions are not completed within the period specified in the approval of the Energy Market Regulatory Authority (“Authority”), such approval shall become invalid and the transaction cannot be continued without obtaining a new approval. With this amendment, the legal consequences of failure to complete the relevant transactions within the period granted by the Authority has been clarified.
     Similarly, with respect to the licensed generation facilities, it has been stipulated that generation facilities that have been partially or fully commenced operations can be transferred. If such transfer is not completed within the period determined by the Authority, which cannot be shorter than six months, the relevant approval shall become null and void.
  3. Regulations on Procedures and Timeframes in YEKA (Renewable Energy Resource Area) Processes: In general, the regulations applicable to YEKA projects have been aligned with the Renewable Energy Resource Areas Regulation² (“YEKA Regulation”) by making explicit references thereto, ensuring consistency between the YEKA framework and the electricity market licensing legislation.
     

     If the termination of a YEKA agreement is notified by the Ministry of Energy and Natural Resources (“Ministry”) to EMRA, the preliminary licence and generation licence granted for the relevant YEKA project may also be cancelled. Further, the duration of preliminary licences granted for YEKA projects may be extended subject to the favourable opinion of the Ministry.

  4. Procedure in Case of Site Overlaps with respect to Unlicensed Generation Facility Applications: While the principle that an unlicensed generation application may not be submitted for a site that is subject to a preliminary licence or generation licence application continues to apply, the amendment provides that where an unlicensed generation facility application intersects with or overlaps with a site subject to a preliminary licence or generation licence application, the relevant application shall no longer be returned, but shall instead be processed in accordance with the Regulation on Unlicensed Electricity Generation in the Electricity Market^[3]. Accordingly, the applicant is granted the opportunity to revise the planned project area and resubmit the application, provided that the connection is made to the same transformer substation or transmission region. As a result, rather than projects being entirely cancelled due to site overlap, the amendment enables a greater number of projects to be implemented through project modification.

  5. Regulations on the Supply and Aggregator Licences: It has been regulated that the amount of energy to be supplied to the system by the facilities operated under supply or aggregation licences may not exceed the electrical installed capacity of the facility that has been approved, and that, where excess energy is supplied, the relevant transactions shall be processed in accordance with Article 12 of the Regulation on the Certification and Support of Renewable Energy Resources (“YEKDEM Regulation”)^[4]. Accordingly, without prejudice to Article 5/7 of the Regulation on Electricity Storage Activities (“Storage Regulation”)^[5], it has been provided that the amount of energy supplied for settlement purposes in excess of the maximum generation amount shall not be taken into account in the settlement calculations of the relevant market participant and shall be deemed as electricity supplied to the system free of charge.

2. Key Developments under the Balancing and Settlement Regulation^[6] (“BSR”):

As per the recent amendments, if legal entities holding a generation licence want to include eligible consumers in their portfolios, now at least one of the generation facilities/units in their portfolios must be registered as a settlement supply/draw unit. 

The amendments also introduce significant regulations concerning aggregation activities. It has been regulated that, in case a legal entity obtains an aggregation licence or aggregation activity is added to an existing licence, the balancing responsible group relationships of such entity shall now change automatically. Accordingly, if the relevant legal entity is a member of a balancing responsible group, it shall be removed from such group. If it operated as the “ responsible party” on behalf of a balancing group, the relevant group shall be dissolved. With respect to aggregator portfolios, it has further been regulated that a consumer may not be included in the portfolios of more than one aggregator; and where categories are created for the purpose of conducting separate settlement calculations, such facilities may not be included in any aggregator portfolio.

Another significant development introduced by the amendments is the available capacity notification, as defined under the newly added Article 69/A. As per this provision, each market participant is required to notify TEİAŞ by 15:30 each day of the maximum power it can technically supply to and/or draw from the system. It has further been provided that, in the event of (i) incomplete or non-submission of available capacity notifications, (ii) making it habitual practice to reduce available capacity through the entry of fault or maintenance records, or (iii) the submission of false notifications or execution of misleading transactions in the balancing power market, TEİAŞ shall notify the Authority in order for measures to be taken pursuant to Article 16 of the Electricity Market Law No. 6446.

With the amendments introduced in the first half of 2025, electricity storage units were included in the settlement system and the principles governing the obligation of availability were determined. In addition, where eligible consumers are requested through the Market Management System (PYS) by more than one supplier, such consumers were granted the right to choose, and, as an important step towards enhanced transparency, mandatory consumer information requirements were introduced. It was also stipulated that market participants failing to fulfil their collateral obligations may not continue their activities. Considering together with these recent changes, it is evident that TEİAŞ will supervise the market strictly going forward, particularly with respect to available capacity transactions .

3. Developments under the YEKDEM Regulation

Recent changes clarified the mechanism regarding the utilisation of electricity generation facilities with battery systems and integrated storage units from the Renewable Energy Support Mechanism (known as “YEKDEM”). Going forward, in case the energy generated and stored while within the scope of YEKDEM is supplied to the grid after such facilities exit YEKDEM, such energy shall not be taken into account in the YEK settlement amount calculations.

Significant changes have also been introduced with respect to the calculation of the YEK charge. In this context, the YEK charge calculation set out under Article 18 has been revised to include YEKDEM revenues, and it has been stipulated that, on public holidays listed under Law No. 2429 on National and Public Holidays (excluding Sundays), if electricity is supplied to the system in excess of the notified Day-Ahead Production Program (KGÜP), the amount of generated electricity exceeding the KGÜP shall not be included in the YEK settlement amount calculations.

For wind- or solar-based electricity generation facilities with storage that commenced operations after 1 May 2023, it has been provided that the price applicable to the energy supplied to the system shall be the price specified under Annex-1(e) of Presidential Decision No. 7189 for “wind- or solar-based generation facilities integrated with electricity storage facilities”. In this respect, in case the energy is supplied to the system without being stored, the applicable tariff for wind-based or solar-based generation facilities shall apply depending on the resource type. Integrated storage units have been excluded from the scope of this changes.

4. Developments under the Storage Regulation

One of the most significant developments introduced under the Regulation on Electricity Storage Activities in the Electricity Market^[7] is the introduction of the right to establish electricity storage facilities for unlicensed electricity generation facilities. Accordingly, it is now possible to establish storage facilities for unlicensed generation facilities that have received a call letter under the Regulation on Unlicensed Electricity Generation in the Electricity Market and are subject to net metering pursuant to Article 26 thereof. When energy is supplied to the grid from such facilities, (i) no payment shall be made for the portion of surplus energy that is supplied from the storage after netting, and (ii) no payment shall be made for the entire surplus energy, if the amount supplied from storage cannot be determined. In these cases, such provided energy shall be deemed as a free-of-charge contribution to YEKDEM.

There is no change in the principle that the amount of energy to be supplied to the system by electricity generation facilities with storage units and by power plants having integrated storage facilities may not exceed the generation amount corresponding to the total electrical installed capacity of the units whose provisional acceptance based on the main resource has been completed. However, for generation facilities whose main resource has not been partially or fully commenced operations, , provided that (i) the system operator deems it technically appropriate and (ii) the conditions determined in this respect are complied with, it is now allowed that any energy may be supplied to the grid up to the accepted portion of the storage unit or storage facility, without exceeding the electrical installed capacity of the main resource registered with the generation licence.

It has further been regulated that the amount of energy to be supplied to the system by the independent electricity storage facilities on a settlement-period basis may not exceed the amount corresponding to the electrical installed capacity of the accepted storage facility, and that any excess energy supplied shall be deemed a free-of-charge contribution to YEKDEM.

5. Other Key Developments Introduced in 2025

Prior to the amendments dated 29 December 2025, significant regulatory developments were also introduced under the Regulation during 2025. The key developments included, in particular: (i) the introduction of share capital and security deposit obligations for independent electricity storage facilities; (ii) provisions stipulating that security provided shall be recorded as revenue if independent electricity storage facilities incorporated into supply or aggregation licences are not completed within the prescribed period; (iii) the obligations on distribution licence holders to monitor the electricity storage unit(s) of electricity generation facilities with storage via SCADA, and to report such data to the system operator through SCADA and settlement-related data to the market operator; and (iv) regulations concerning share transfers.

Another significant amendment introduced in 2025 concerns the transition of electricity meters to a smart metering system. Pursuant to the Energy Market Regulatory Authority’s Decision dated 4 December 2025 and numbered 13995, which was published in the Official Gazette dated 5 December 2025 and numbered 33098; it has been stipulated that electricity meters across Türkiye shall be replaced with smart meters in phases, effective as of 1 March 2026. Further, the principles governing the replacement of meters that have reached the end of their periodic inspection period have also been clarified.

As per the relevant decision, distribution companies are now obliged to install “Smart Meter PRO” and “Smart Meter EKO”, the latter having limited functionalities compared to the Smart Meter PRO.

Accordingly, existing meters of consumers whose electricity consumption exceeded 10 MWh either in the previous year or during the current year shall be replaced with Smart Meter PRO by the relevant distribution company. For the users below such threshold, Smart Meter EKO must be installed. As per the decision, 70% of all meters must be replaced by 1 January 2027 and 100% of all meters must be replaced with the new ones by 1 January 2028.

Further, distribution companies are now imposed with an obligation to remedy, within the prescribed periods, meter-related issues arising from software and/or hardware in meters equipped with remote communication capabilities. The regulation also provides that issues related to data queries caused by access problems to mobile applications or internet systems shall be identified and recorded by EPİAŞ, and that EPİAŞ shall carry out corrective actions within the timeframes set out under the relevant decision. Where the requested data cannot be provided to EPİAŞ in the required format, corrective action shall be taken by the distribution company within 48 (forty-eight) hours following receipt of the notification, in order to eliminate the issue.

^[1] published in the Official Gazette dated 2 November 2013 and numbered 28809.

^[2] published in the Official Gazette dated 9 October 2016 and numbered 29852.

^[3] published in the Official Gazette dated 12 May 2019 and numbered 30772.

^[4] published in the Official Gazette dated 1 October 2013 and numbered 28782.

^[5] published in the Official Gazette dated 9 May 2021 and numbered 31479.

^[6] published in the Official Gazette dated 14 April 2009 and numbered 27200.

^[7] published in the Official Gazette dated 9 May 2021 and numbered 31479.