1. Introduction
Climate change and the ensuing climate crisis have evolved into a global issue that necessitates future action plans and the assumption of responsibility by states, institutions, and individuals alike.
In this context, Türkiye has taken its first significant step with the enactment of Climate Law No. 7552, which was adopted by the Grand National Assembly of Türkiye on 2 July 2025 and entered into force upon its publication in the Official Gazette on 9 July 2025. With this legislation, the country has established a legal foundation for fighting against the climate crisis. Accordingly, many aspects that had previously been defined merely as “targets” have now been transformed into “obligations.”
The primary objective of the Climate Law is to ensure that Türkiye’s fight against climate change is conducted in an effective, sustainable, and equitable manner in line with the 2053 Net Zero Emissions Target, and to provide a legal framework to this end. The Law adopts the internationally recognized principle of “common but differentiated responsibilities and respective capabilities.”
2. Emissions Trading System (ETS)
A notable provision introduced by the Law is the establishment of an Emissions Trading System (ETS) in Türkiye for the first time. Through the allocation and trading of emission allowances, the system aims to limit or reduce greenhouse gas emissions using market-based mechanisms.
3. Carbon Markets
Carbon markets are structured as financial mechanisms to be managed and regulated by authorized market operators. Under the national ETS, both primary and secondary markets will be organized and activated for the trading of allowances as well as standardized contracts related to emissions trading. The authority responsible for operating this system and maintaining the market infrastructure will be Enerji Piyasaları İşletme Anonim Şirketi (EPİAŞ).
Additionally, Voluntary Carbon Markets will allow for the free trading of carbon credits among individual and institutional actors based on the principle of voluntariness. Registration of projects related to these markets by the designated authority has been made mandatory. Through the operation of voluntary carbon markets, Türkiye also aims to strengthen its integration into international carbon trading systems and contribute to the development of effective policies in this field.
4. Greenhouse Gas Emissions Permit
Enterprises expected to fall under the scope of the ETS are required to obtain a greenhouse gas emissions permit within three years from the effective date of the Law. During this transitional period, these enterprises will be deemed to possess a one-time valid emissions permit in order to continue their operations within the scope of the ETS. This regulation is intended to facilitate the transition to the system and to support the phased implementation of the ETS.
5. Protection of Agricultural and Natural Areas
Article 5 of the Law stipulates the prevention of carbon sink losses in forest, agricultural, pasture, and wetland areas, as well as the protection and enhancement of such areas. These ecosystems play a critical role in achieving the net zero emissions target by naturally capturing greenhouse gases from the atmosphere. The Law also envisages that climate-resilient crop patterns will be developed in the agricultural sector, planning will be conducted with consideration of the water budget, and nature-based solutions will be promoted. It also aims to expand the implementation of climate-resilient practices in agriculture and to ensure food security.
6. Powers and Responsibilities
The Law establishes the Directorate of Climate Change, which is vested with duties such as monitoring greenhouse gas emissions, preparing strategies and action plans, and regulating carbon pricing mechanisms. Moreover, a Provincial Climate Change Coordination Board is to be established in each province. These boards will be responsible for the preparation of local climate action plans.
a) Public Institutions
While the Directorate of Climate Change assumes a central coordinating role, it is mandatory to establish Provincial Climate Change Coordination Boards at the local level.
Ministries are granted duties and powers including policy formulation, regulation of carbon markets, and authority to request data.
Local administrations are obliged to prepare their climate action plans by the end of 2027.
b) Private Sector
Enterprises falling within the scope of the ETS are required to obtain a greenhouse gas emissions permit within three years.
The national ETS regulates the trading of allowances and carbon credits. Under this system, enterprises are allocated a specific amount of emission allowances, which must be surrendered in accordance with their annual emission levels.
c) Natural and Legal Persons
Natural persons and civil society organizations also assume a role in the fight against climate change under the Climate Law. In this respect, the obligation to comply with measures adopted under climate policies that serve the public interest is not limited to public institutions and the private sector, extending to individuals and societal organizations. The Directorate of Climate Change is authorized to request information and documentation directly from these actors when deemed necessary.
7. Sanctions
The Law stipulates that administrative sanctions and monetary fines will be imposed in cases of non-compliance with obligations. In this context, enterprises that fail to submit their emissions reports may be fined between TRY 500,000 and TRY 50 million. Additionally, measures such as the revocation of emissions permits or the temporary suspension of new permit applications have also been laid down. Violations that may give rise to penal sanctions include the failure to submit verified emissions reports on time, non-compliance with fluorinated gas regulations, failure to report required information to the database, or the continuation of ETS-related activities without a valid permit. However, administrative fines imposed for violations committed during the pilot phase prior to the full implementation of the ETS will be subject to an 80% reduction. Furthermore, the Directorate of Climate Change has been vested with the power to develop market-based carbon pricing mechanisms.
Conclusion and Opinion
Climate Law No. 7552 introduces provisions that will directly impact Türkiye’s foreign trade policies. In particular, the provision concerning the establishment of a Carbon Border Adjustment Mechanism (CBAM) for managing the carbon footprint of imported products mandates a strategic transformation for export-oriented sectors. This mechanism aims to create a framework aligned with the European Union’s CBAM practices and may result in additional costs and reporting obligations for the export of carbon-intensive products. Therefore, foreign trade enterprises will be required to decarbonize their production processes and adopt carbon pricing systems.
The Law introduces several new practices, such as the promotion of environmentally friendly production systems, the establishment of carbon markets, and the preparation of local climate action plans. However, the regulation has also been subject to criticism for prioritizing market-based instruments while offering limited mechanisms for public participation. In this regard, the implementation phase of the Law will be decisive for the success of Türkiye’s climate policies.
Birgi Kuzumoğlu, Partner
