Türkiye’s First Climate Law Adopted: A New Legal Framework for the Green Transformation

On 2 July 2025, Türkiye’s first-ever Climate Law (the “Law”) was adopted by the Turkish Grand National Assembly and, following presidential approval, entered into force upon its publication in the Official Gazette on 9 July 2025. This landmark legislation introduces a comprehensive legal framework governing climate policy, carbon markets, and green finance.

The Law marks a significant milestone in Türkiye’s alignment with international climate goals and its transition toward a low-carbon economy. Grounded in a vision of "green development", the Law affirms Türkiye’s commitment to achieving a net-zero emission target and is based on key principles including intergenerational equity, policy integration, climate justice, and the doctrine of common but differentiated responsibilities as established by the United Nations (UN).

Strategic Vision and Institutional Climate Planning

The Law mandates that emission reduction efforts be conducted in accordance with sector-specific targets, as outlined in Türkiye’s Nationally Determined Contribution (NDC). In line with Article 6 of the Law, relevant public institutions will be responsible for overseeing and implementing these targets. These efforts will also align with Türkiye’s long-term climate strategy, climate action plans, and sectoral roadmaps, as further detailed under Article 6/2.

Furthermore, under Article 7, public institutions are now required to prepare, implement, monitor, and periodically revise their mid-term and long-term strategic plans in accordance with national emission reduction targets. Specifically, all public institutions and organizations must adapt their strategic and action plans by 31 December 2027, with local climate action plans also required to be prepared within this timeframe. The specific roles and obligations related to these institutional responsibilities will be further clarified in forthcoming secondary legislation.

Establishment of Emissions Trading System (ETS)

A central feature of the Law is the creation of an Emissions Trading System (ETS), a market-based mechanism that sets an upper limit (cap) on greenhouse gas emissions to support the net-zero target. The ETS will be administered by the Climate Change Presidency and will include: (i) allowance allocation mechanisms, (ii) emission permitting procedures, (iii) offset schemes, and (iv) market stability measures, in accordance with Articles 9 and 10.

Drawing inspiration from the European Union’s Carbon Border Adjustment Mechanism (CBAM), the Law establishes the framework for a national mechanism to account for the carbon intensity of imported goods. Pursuant to Article 8, the Ministry of Trade, in cooperation with other relevant ministries, will issue the technical and reporting rules governing the national CBAM.

Facilities responsible for direct greenhouse gas emissions are now required to obtain emission permits as per Article 9. Any changes in activity, capacity, or ownership must be reflected in updated permit records. Entities subject to the ETS will be required to submit verified annual emission reports and surrender allowances accordingly. Secondary legislation is expected to further clarify the scope and application of these obligations.

To support climate mitigation and adaptation efforts, the Law promotes the development of financial instruments such as green bonds, sustainability-linked loans, and climate risk insurance mechanisms. Outlining the regulatory support and incentives with Article 11, the Law seeks to expand Türkiye’s climate finance ecosystem. The Ministry of Treasury and Finance is authorized hereunder to develop financial mechanisms and to support the issuance of sustainable finance instruments by both public and private entities.

Under Article 14, violations of the Law may result in administrative fines ranging from TRY 500,000 to 10 million, and restrictions related to emissions and regulated substances. Stricter penalties apply to ETS participants, including suspension of allowance transfers and permit cancellations, with fines escalating for repeated offenses. Prior to full ETS implementation, a pilot period will apply during which fines are discounted by 80%. The Law also allows corrective periods before enforcement actions are taken, and maximum fines for a single violation can reach TRY 50 million.

Implementation Timeline and Stakeholder Engagement

The Law provides for transition periods and an implementation calendar for certain obligations, which are critical for adaptation by both public institutions and the private sector. For instance, in addition to the deadline specified for public institutions to adapt their strategic and action plans by 31 December 2027, facilities subject to ETS have a three-year transition period from the Law’s entry into force, requiring them to obtain emission permits within this timeframe. Clarified through secondary legislation, this calendar will enable the gradual enforcement of the obligations.

Moreover, the Law adopts a participatory approach in the development and implementation of climate policies. It encourages active involvement from stakeholders such as the private sector, NGOs, and academia, aiming to enhance the legitimacy and effectiveness of climate governance.

Climate Adaptation, Risk Management, and Climate Impact Assessments

The Law introduces a national framework for climate adaptation activities to address both current and potential climate-related risks and losses. Specific institutions will be assigned implementation duties through subsequent regulations.

In order to enhance climate resilience, the Law calls for climate risk and vulnerability assessments to be conducted at both the national and sectoral levels, in line with Article 10.

Additionally, the Law lays the groundwork for “Climate Impact Assessment” processes, which require evaluations of the climate-related effects of projects and investments, similar to existing environmental impact assessments.

Oversight, Enforcement, and the Türkiye Green Taxonomy

Under Article 8, the Climate Change Presidency is tasked with issuing national, sectoral, and thematic climate reports, developing incentive mechanisms, and creating a Türkiye Green Taxonomy in this respect. The Law also promotes circular economy principles by imposing obligations on product reuse, secondary use of waste, and minimum thresholds for recycled materials.

The Climate Change Presidency is authorized to conduct inspections and audits, impose administrative sanctions, and oversee enforcement of the Law’s provisions in accordance with Article 15.

Green Transformation and Just Transition

The Law underscores the principle of a just transition, placing particular emphasis on supporting strategic sectors impacted by climate regulations. Social equity and the fair distribution of the costs and benefits associated with the green transformation are embedded as core values in Article 5 of the Law.

Overall, Türkiye’s Climate Law introduces a robust legal framework to guide the country’s transition to a low-carbon future. With binding obligations, marked-based instruments, and a range of financial and strategic incentives, the Law lays a solid foundation for climate governance. As secondary legislation is expected to follow, the legal and regulatory landscape for climate governance will continue to evolve — offering new responsibilities and opportunities for both the public and private sectors.