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Energy Law

Legal support for license, permit, contract and financing processes in energy investments, and for operation, regulatory compliance and disputes.

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From investment to operation

The legal structure of an energy project is assessed across all of its stages.

Electricity, renewable energy, natural gas, oil, LPG, storage, charging networks, energy efficiency and carbon markets involve interrelated permits, contracts and regulatory obligations. Obtaining a license does not mean that the conditions for land access, connection, environment and financing have also been completed.

Güneş & Güneş Law Firm provides legal services to investors, project developers, producers, suppliers, contractors, financial institutions and technology providers in project development, licensing, contracts, investment transactions, compliance and dispute resolution.

The project’s technical, commercial, financial, environmental and real-estate-related risks are addressed together with the work of the relevant experts. In each file, the tasks to be done, responsibilities and priority time limits are determined.

Is there an official notification or a project time limit?

Preserve the letter from the Energy Market Regulatory Authority (EPDK), the penalty, the connection call letter (çağrı mektubu), the contract notice and the record of notification. The nature of the decision and the last date for action should be examined at the first stage.

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Scope of our services

Our Energy Law services

Choose the area that fits the stage of your project or the issue you are facing. In each section you can see the scope of the legal work and the related transactions.

Investment, licensing, financing and corporate transactions

4 areas of work

Structuring energy investments and project development

The company structure of the energy investment, the project company, the shareholding model, the investment timetable, the financing method and the regulatory requirements are examined together. A legal road map is prepared according to the energy source and type of activity in which the project will be developed; whether the investment will proceed through acquisition, a joint venture, an asset transfer or greenfield development is assessed.

  • Legal structuring of the project company and the investment model
  • Review of investment legislation for domestic and foreign investors
  • Preparation of joint venture, shareholders’ and project development agreements
  • A project road map covering the license, permit, land, connection and environmental processes
  • Review of the legal conditions of investment incentives and support mechanisms
  • Project risk matrix, legal due diligence and pre-transaction checklists

Depending on the project’s model, a review connected with competitions, tenders, concessions, operating rights, build-operate-transfer or public-private partnership contracts may also be carried out. It is not assumed that all energy projects are subject to the same tender rules.

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EPDK licenses, pre-license (önlisans) procedures and regulatory permits

In the electricity, natural gas, oil, LPG and charging service markets, the pre-license, license, certificate, permit, notification and approval obligations differ according to the type of activity. The application should not be regarded merely as the procurement of documents; it needs to be planned together with the ownership structure, capital, share transfers, change of control, security, the facility program and technical obligations.

  • Legal preparation and review of pre-license and license application files
  • Management of license amendment, term extension, termination and cancellation processes
  • Regulatory assessment of share transfers, direct or indirect changes of control and corporate transactions
  • Follow-up of EPDK information and document requests and inspection processes
  • Monitoring of license obligations, security requirements and project progress conditions
  • Assessment of the routes of application and litigation against regulatory authority decisions, administrative sanctions and licensing actions

Project finance and security structure

In the financing of energy investments, the lenders’ expectations of security over project revenues, assets and contracts should be balanced against the sponsors’ limits of liability.

  • Review and negotiation of loan and project finance agreements
  • Legal due diligence and bankability review from the bank’s perspective
  • Structuring of share, account, receivable, equipment and real property security
  • Direct agreements and the lender’s step-in rights
  • Conditions precedent to financing, and permit and contract closing lists
  • Refinancing, debt restructuring and changes to security
  • Legal review of sustainable finance and green finance documents

Mergers, acquisitions and legal due diligence in energy companies

When an energy project or company is acquired, the license, land, connection, zoning, environmental, incentive, equipment and principal project contracts should also be reviewed in addition to the company records.

  • Buy-side or sell-side legal due diligence
  • Transferability of project rights, licenses, permits and contracts
  • EPDK and other authority approvals, and share or change-of-control processes
  • Competition law and merger-acquisition notifications
  • Share sale, asset transfer, joint investment and closing documents
  • Representations and warranties, indemnification provisions, price adjustment and post-closing obligations
  • Distressed projects, restructuring and investment exit transactions

Electricity, renewable energy and storage

3 areas of work

Electricity market law

Electricity generation, transmission, distribution, supply, aggregation, storage, market operation and consumption relationships also involve connection, system use, settlement, security and market participation obligations, in addition to licensing.

  • Legal structuring of generation and supply activities
  • Review of licensed and unlicensed electricity generation projects
  • Assessment of self-consumption, rooftop and ground-mounted generation models
  • Connection applications, connection and system use agreements
  • Relations with TEİAŞ (Turkish Electricity Transmission Corporation), distribution companies, supplier-of-last-resort companies (görevli tedarik şirketleri) and other market actors
  • Contract and settlement disputes connected with the day-ahead, intraday and balancing power markets
  • Ancillary services, the capacity mechanism, security and market participation processes
  • Disputes over interruptions, curtailment, connection capacity, losses and unauthorized electricity use, meters and consumption
  • Electricity market relationships in organized industrial zones and industrial zones

Renewable energy projects

Solar, wind, hydroelectric, geothermal, biomass and biogas projects carry risks specific to each, in terms of resource rights, measurement, connection, land, zoning, environment, incentives and equipment supply. Each project is assessed within the regulatory framework appropriate to the nature of the resource and the installed capacity.

  • Solar power plants (GES), wind power plants (RES), hydroelectric power plants (HES), geothermal power plants (JES), biomass and biogas projects
  • Legal review of Renewable Energy Resource Area (YEKA) competitions and YEKA agreements
  • Assessment of the Renewable Energy Support Mechanism (YEKDEM) and other renewable energy support mechanisms
  • The YEK-G certificate and renewable energy guarantee-of-origin procedures
  • Legal review of domestic components, resource verification and support conditions
  • Project development, measurement, site use and connection agreements
  • Unlicensed generation, offsetting (mahsuplaşma), pairing with a consumption facility and self-consumption models
  • Transfer of power plants, acquisition of projects and legal due diligence

YEKDEM status is examined separately according to the application year, the commissioning date and the support conditions. YEKA, YEKDEM and YEK-G do not substitute for one another.

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Energy storage, hybrid facilities and new energy technologies

Electricity storage units, stand-alone storage facilities, storage integrated into a generation facility and auxiliary-source generation projects are addressed in terms of licensing, connection, capacity allocation, equipment, performance and cybersecurity.

  • Review of the license and project structure of storage investments
  • Battery supply, performance warranty, capacity loss and warranty agreements
  • Regulatory assessment of hybrid and auxiliary-source facilities
  • Connection capacity, system use and market participation relationships
  • Contractual structure of aggregation, demand-side participation and flexibility services
  • Analysis of the existing legislation and permit structure for hydrogen, biomethane and other emerging energy solutions

The April 2, 2026 amendment contains special provisions for storage integrated into an unlicensed generation facility. The price of surplus energy from storage fed into the grid, and the metering distinction, are assessed separately in the investment revenue assumptions.

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Natural gas, oil, LPG and nuclear energy

3 areas of work

Natural gas market law

Natural gas import, export, transmission, storage, wholesale, distribution, compressed natural gas and LNG activities are assessed together with the licensing, capacity, system use, supply and balancing regulations.

  • Natural gas market licensing and permit procedures
  • Import, export, wholesale, storage, CNG and LNG contracts
  • Access to the transmission and distribution systems, and capacity and use relationships
  • Long-term and spot natural gas supply contracts
  • Take-or-pay, price revision, capacity, quality and delivery disputes
  • Natural gas distribution, connection, subscription and consumption disputes
  • Legal follow-up of procedures before the Petroleum Pipeline Corporation (BOTAŞ), EPDK and other relevant authorities

Oil, fuel, LPG and hydrocarbon activities

Oil exploration and production activities, together with refining, transmission, storage, distribution, dealership and LPG market transactions, fall within the remit of different laws and authorities. It is important that the contract and license structure be established in line with the activity chain.

  • Legal review of petroleum rights, exploration and production activities
  • Refiner, distributor, storage, transmission, dealership and LPG licensing procedures
  • Fuel dealership, usufruct, lease, supply and investment agreements
  • National marker, automation, stock and market obligations
  • Disputes over price, quality, delivery, shrinkage, stock and product liability
  • EPDK inspections, license sanctions and administrative fines
  • Coordinated assessment of the administrative, commercial and criminal law aspects of smuggling allegations

Nuclear energy and advanced energy projects subject to regulation

Nuclear energy investments are subject to a special regulatory structure in terms of nuclear safety, radiation protection, authorization, safeguards, security, waste management and third-party liability.

  • Legal review of authorization processes before the Nuclear Regulatory Authority (Nükleer Düzenleme Kurumu)
  • Assessment of project, EPC, supply, technology, operation and maintenance contracts
  • Nuclear liability, insurance and risk allocation provisions
  • Radiation applications, waste and service provider contracts
  • Joint assessment of international conventions and Turkish legislation

Land, zoning, environment and the end of the facility

3 areas of work

Land acquisition, zoning, expropriation and facility permits

The energy project’s access to the site is examined in terms of ownership, easements, leases, rights of use, zoning, construction permits, forest, pasture, agricultural land and environmental permits. A land registry review does not consist solely of owner information; annotations, easements, attachments, mortgages, lawsuits, the cadastral survey and actual use should also be assessed.

  • Review of the land registry, the cadastral survey, zoning and encumbrances
  • Purchase, lease, superficies and easement agreements for privately owned land
  • Permits for Treasury real property, forest, pasture and agricultural land
  • Zoning plans, plan amendments, construction permits and occupancy permits
  • Zoning and permit procedures for wind and solar facilities
  • Easement and expropriation processes for energy transmission lines, pipelines and facility sites
  • Expropriation, urgent expropriation, determination of compensation and registration actions
  • Disputes over land access, neighboring properties, passage, interference and possession

The July 24, 2026 regulation governs the Ministry’s zoning and permit authority in pre-licensed or generation-licensed wind (RES) and solar (GES) projects within its scope. No automatic transfer of existing files, or exemption from all permits, can be inferred.

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Environment, ÇED and sector-specific permits

Environmental impact assessment, environmental permits and licenses, emissions, waste, water use, protected areas and natural assets directly affect the feasibility of developing energy projects.

Our law firm does not take the place of the organization that prepares the ÇED report or a technical environmental report. It assesses the legal framework of the studies prepared by authorized technical consultants, the permit process, participation and notification obligations, administrative decisions and possible disputes.

  • Legal road map of the ÇED process and review of decisions
  • Coordination of environmental permits and licenses with other sector-specific permits
  • Legal assessment of administrative applications, public participation and agency opinions
  • Administrative applications and lawsuits against ÇED, environmental permit, protection and conservation-site (sit) decisions
  • Environmental obligations, pollution, rehabilitation and closure liability
  • Contractual and legal review of the reports of technical consultants, engineers and environmental experts

Facility closure, termination of the license and environmental obligations

If the economic life of the energy facility ends, the license is terminated or the investment is abandoned, the obligations relating to dismantling, site rehabilitation, waste, employees, contracts and security are planned together.

  • Termination of licenses and permits
  • Dismantling of the facility, handover of the land and rehabilitation obligations
  • Equipment sale, recycling and waste procedures
  • Closing out employee, supplier and financing agreements
  • Release of security and management of remaining liabilities

Energy contracts, charging services and efficiency

3 areas of work

Energy contracts

In energy projects, the consistency of the contracts with one another is decisive for the project’s bankability and operating continuity. A delivery, performance, force majeure or termination provision in a single contract may also affect the obligations in the other project contracts.

In the contracts, the provisions on price and price adjustment, delivery, capacity, performance testing, acceptance, delay, contractual penalty, warranty, change orders, force majeure, change in legislation, termination, limitation of liability and dispute resolution are addressed within the project as a whole.

  • Electricity sale and supply agreements, and corporate power purchase agreements (PPAs)
  • Supply contracts for natural gas, oil, fuel and other energy products
  • EPC, turnkey, construction and engineering contracts
  • Equipment supply, technology license, installation and commissioning contracts
  • Operation and maintenance (O&M), long-term service agreement (LTSA) and technical service contracts
  • Project development, measurement, consulting and management contracts
  • Connection and system use agreements
  • Land purchase, lease, superficies and easement agreements
  • Joint venture, shareholders’, share transfer and asset transfer agreements
  • Direct agreements, guarantee, suretyship, security and insurance documents

Electric vehicle charging networks and charging services

Charging network operation is subject to special regulations in terms of licensing, relations with charging station operators, certificates, pricing, remote access, data sharing, consumer transactions and technical standards.

  • Charging network operator license applications and licensing procedures
  • Charging station installation, operation, use and revenue sharing agreements
  • Relationships among the property owner, the housing complex management, the parking operator and the station operator
  • Software, platform, roaming, payment and data sharing agreements
  • Legal review of consumer transactions, price notices and service terms
  • EPDK regulations, charging network obligations and inspection processes

Operating a charging network and operating a station under a certificate obtained from a network are different structures. Current payment and user information requirements are reflected in the contracts.

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Energy efficiency and energy performance contracts

In industrial facilities, commercial buildings and public projects, energy efficiency investments require that performance measurement, the savings guarantee, financing and equipment liability be clearly regulated.

  • Energy performance contracts and energy service company models
  • Legal assessment of efficiency-enhancing projects and support conditions
  • Measurement and verification, savings sharing and performance guarantees
  • Cogeneration, trigeneration and on-site generation models
  • Equipment financing, maintenance and performance disputes

Climate, regulatory compliance, litigation and arbitration

3 areas of work

Climate law, the emissions trading system and carbon markets

The emissions trading system developing under the Climate Law, greenhouse gas emission permits, monitoring-reporting-verification obligations and carbon markets are creating new compliance and contracting needs for energy producers and energy-intensive businesses.

  • Assessment of compliance with the Climate Law and secondary regulations
  • Preparations for the emissions trading system and the greenhouse gas emission permit
  • Legal review of monitoring, reporting and verification relationships
  • Carbon credit development, purchase, sale and project contracts
  • YEK-G, green energy claims and the contractual use of environmental attributes
  • The contractual, supply and price effects of carbon border regulations
  • Review of the risks of misleading environmental claims and greenwashing

The 2026 TR ETS and Türkiye Green Taxonomy regulations are examined together with facility scope and transitional provisions. YEK-G, carbon credits and emission allowances are different legal instruments.

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Regulatory compliance, inspections and sanctions

In energy companies, the compliance program needs to be tailored to the field of activity. Competition, market conduct, personal data, cybersecurity and corporate governance rules should be taken into account as much as license obligations.

  • EPDK inspections and information and document requests
  • Administrative fines, suspension of activity and license sanctions
  • Market-distorting conduct and energy market integrity investigations
  • Competition law, vertical agreements, exclusivity and dominant position risks
  • Internal control, authority matrix, record retention and whistleblowing mechanisms
  • Critical infrastructure, cybersecurity, trade secrets and personal data protection
  • Sanctions, export control and anti-money laundering controls
  • Preventive advice on the liability of the board of directors and managers

Energy disputes, administrative actions and arbitration

In energy disputes, the court with subject-matter jurisdiction, the applicable law, the arbitration clause, the time limits and the need for interim legal protection should be determined at the start of the file. The same event may give rise to regulatory, commercial, technical and criminal consequences.

  • Applications against EPDK decisions, licensing actions and administrative sanctions
  • Actions concerning ÇED, zoning, permits, expropriation and other administrative acts
  • Disputes over connection capacity, system use, interruptions and curtailment
  • Balancing, settlement, security, invoicing and market transactions
  • PPA, supply, price adjustment, take-or-pay and delivery disputes
  • EPC, equipment, delay, performance test, defect and warranty disputes
  • Land, easement, expropriation and facility access disputes
  • Share transfer, investment, shareholder and project finance disputes
  • Insurance, damage, recourse and business interruption claims
  • National and international arbitration, mediation and commercial litigation processes
  • Interim injunctions, precautionary attachment, preservation of evidence and other interim protection requests
  • Recognition and enforcement (tenfiz) of foreign arbitral awards, and execution of decisions

Legal framework

Distinctions that should be clarified before an investment decision

More than one permit and contractual relationship may exist together in the same project. The distinctions below help in establishing the work plan.

Distinctions among permits, documents and applications in energy projects
SubjectBasic differenceFocus of the review
Pre-license / generation licenseThe pre-license is the stage aimed at completing the preparations and permits required for the project. The generation license governs the authority to carry on the activity under its own conditions.Zoning, ÇED, land and connection conditions are monitored separately.
Licensed / unlicensed generationUnlicensed generation rests on exceptions in the law and regulation.The consumption relationship, capacity, connection and offsetting conditions do not disappear.
YEKA / YEKDEM / YEK-GYEKA is a resource area and competition model; YEKDEM is a support mechanism, and YEK-G is the renewable energy guarantee-of-origin system.Being included in one does not confer all the rights in the other.
Charging network license / station certificateThe charging network operator is the license holder. A station may be operated under the network operator’s certificate.Land, connection, software, payment and user responsibilities are regulated separately.
ÇED / other facility permitsÇED is an environmental assessment process.A positive decision does not replace zoning, construction, forest, pasture, agricultural or other permits.
Carbon credit / allowance / YEK-GA carbon credit relates to a reduction or removal project; an allowance relates to the ETS emission right; and YEK-G relates to the renewable source of the electricity.The transfer and use of the certificate and the environmental claim should not be confused with one another.
EPDK decision / contract disputeA regulatory act and a private-law contract may give rise to different routes of application.Subject-matter and territorial jurisdiction, time limits and arbitrability are determined at the start of the file.

Notes on current legislation

Developments affecting energy projects

The effect of regulatory changes on the permit calendar, financing, operation and contractual responsibilities is assessed project by project.

Türkiye Green Taxonomy

September 24, 2026

The regulation entered into force upon publication. The environmental contribution, not causing significant harm to other objectives, and minimum social safeguard conditions are assessed together. The reporting transition for financial institutions extends to January 1, 2029; in addition, information and reports may be requested from the real sector within the scope of a financing transaction. The financing and environmental claims of the energy investment should be examined within this framework.

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Türkiye Emissions Trading System

August 27, 2026

The TR ETS Regulation entered into force. The facility’s activity, its category, cases outside the scope and the transition of the permit should be addressed together. The announcement of the Presidency states that the scope and duration of the pilot implementation will be determined by the competent board. The calendar in the drafts should not be applied to all facilities as a definitive calendar of obligations.

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Zoning and permits for wind (RES) and solar (GES) plants

July 24, 2026

The new regulation governs the Ministry’s zoning and permit procedures for pre-licensed or generation-licensed wind and solar facilities within its scope. According to the official guide, the authority of other competent administrations is not eliminated entirely; a pending application is not transferred to the Ministry automatically. The authority to which the application is made, the existing file and the real property permits are examined together.

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Direct payment at charging stations

July 1, 2026

According to an EPDK announcement, on highways under the responsibility of the General Directorate of Highways (KGM), the option of direct payment by card or contactless device should be provided for at least one of the DC 50 kW and higher units of stations newly added to the network from this date. No additional commission or difference may be charged for this method. The condition needs to be assessed together with the station’s location, the date it was added and the power of the unit.

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Unlicensed generation and offsetting

April 2 / May 1, 2026

The April 2, 2026 amendment renewed the provisions on connection, acceptance, offsetting and integrated storage. The specified provisions enter into force on May 1, 2026. Hourly offsetting should be distinguished from the monthly offsetting exception for facilities associated with residential subscriptions that have been entitled to a call letter since May 12, 2019. The type of facility, the date of the call letter and the consumption relationship affect the revenue model.

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EU carbon border regulation

January 1, 2026

The definitive period of the Carbon Border Adjustment Mechanism (SKDM/CBAM) has begun; electricity and hydrogen are also among the selected product groups in scope. The obligations of the EU importer are separate from the emissions data and contractual obligations of the producer in Türkiye. The product scope, calculation and transition rules are examined according to the specific trade flow.

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2026 YEKDEM status

Decision dated December 30, 2025

The 2026 final YEK list was issued by EPDK Decision No. 14181-1. In the support assessment for a facility, the list, the license, commissioning and the relevant support conditions are checked. A single price, term or automatic right to support is not assumed for all facilities with the same technology.

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The dates of publication, entry into force and transition may differ. License fees, security requirements, capacity announcements, connection conditions and application calendars are checked again on the date of the transaction. The selected developments here are not a complete list of all energy legislation or of the conditions that will apply to each project.

Source review and preparation date: October 4, 2026. Legislation, announcements of authorities and application conditions are assessed together.

Initial assessment

To protect rights and project time limits

If there is an upcoming decision, contract or authority time limit, state it clearly in your consultation request.

A license or administrative sanction has been notified

Keep the decision, its annexes and the record of notification. The time limits and conditions for the options of objection, defense, filing an action and a stay of execution are examined together.

A connection or investment time limit is approaching

Compare the call letter, the connection agreement, the pre-license conditions and the realization timetable. Assess the options regarding missing documents, extension and notification before the time limit expires.

Generation, delivery or payment has been disrupted

Preserve the interruption record, meter data, settlement notice, invoices and contract correspondence. Have the notice, security and loss mitigation obligations reviewed.

There is a project acquisition or financing signing

Create a document list for the license, land, connection, ÇED, incentives, security and principal contracts. Assess transferability and the required permits together with the closing conditions.

The same application time limit does not apply to every act. The effect of an administrative application on the time limit for filing an action may vary according to the type of act and the special regulation. A consultation request does not stop the time limit; nor does filing an action by itself stop the application of the act.

Parties we work with

Which clients do we serve?

The scope of the service is determined according to the party’s role in the project, its authority and the nature of the dispute.

  • Energy investors and project developers
  • Electricity generation, supply, storage and aggregation companies
  • Natural gas, oil, fuel and LPG market actors
  • Charging network operators, station operators and technology providers
  • EPC contractors, subcontractors, equipment manufacturers and service providers
  • Banks, financial institutions, investment funds and insurance companies
  • Industrial facilities, organized industrial zones and large consumers
  • Landowners, contractors and project participants
  • Domestic and foreign companies, entrepreneurs and investors

Our approach

From the initial review to operation and follow-up

The tasks to be done, the responsible persons, the necessary authorization and the work to be delivered are determined in the consultation and the service agreement.

  1. Preliminary assessment and scope of the work

    The resource, activity, installed capacity, company structure, location, permits, connection, financing and target timetable are identified. In a dispute, the decision, the official notification and the existing records are examined.

  2. Legal risk map

    License, land, zoning, environmental, connection, contract and financing risks are ranked by importance and timing. The need for technical and financial expertise is identified separately.

  3. Strategy and implementation timetable

    A sequence is established for the application, contract, corporate resolution, approval and closing conditions. Time limit dependencies and uncertainties are shared with the client.

  4. Management of authorities and contracts

    Files are prepared; contracts are negotiated. The legal process is coordinated with the work of the engineer, environmental consultant, financial adviser (mali müşavir) and valuation expert.

  5. Dispute and closing

    Options of administrative application, litigation, arbitration, mediation and negotiation are assessed. Registration, security, delivery and closing documents are checked.

  6. Operation and regular follow-up

    Notifications, support and license conditions, contractual obligations and legislative changes are followed. Important stages are communicated to the client.

Legal follow-up during the operating period

Obligations continue after the permit is obtained

A control system suited to the company’s activities makes it possible to monitor license, contractual, environmental and notification obligations together.

  • Calendar of licenses, permits, security, reporting and notifications
  • Capacity, connection, acceptance and commissioning conditions
  • Support, domestic component and environmental attribute documents
  • Critical dates in PPA, supply, EPC and maintenance contracts
  • EPDK inspection, competition, market conduct and internal control
  • Critical infrastructure, cybersecurity, trade secrets and personal data
  • Scope of emissions, carbon and taxonomy obligations according to the facility
  • Dismantling, waste, rehabilitation and closure responsibilities

Preparing for a consultation

Documents useful for the initial legal review

Not every document is necessary in every file. A sharing plan suited to the file is prepared on the basis of the existing documents and what is missing.

Company, permits and contracts

  • Company and shareholder documents
  • Pre-license, license, permit, authority correspondence and official notifications
  • Connection opinion, call letter, connection and system use documents
  • Land registry records, lease and easement agreements, zoning and cadastral documents
  • ÇED decision, environmental permits and technical reports
  • PPA, EPC, supply, maintenance, financing and security agreements

Project, record and dispute documents

  • Invoices, settlement notices, metering records and commercial correspondence
  • Administrative decision, inspection report, penalty notice and court filings
  • Project timetable, technical specification, acceptance and performance tests
  • Records concerning YEKDEM, YEKA, YEK-G, carbon and taxonomy, if any
  • Insurance policies, claim notifications and compensation correspondence
  • Timeline of events, upcoming time limits and list of missing documents

A short summary is sufficient at first contact. State the type of project, the province in which it is located, the current stage, the issue and the upcoming time limit. Documents containing trade secrets, personal data or critical infrastructure information should not be attached to a general message to the firm; the secure sharing method is determined in the preliminary consultation.

Working with technical, environmental and financial experts

A law firm does not take the place of the authorized expert who prepares engineering, the ÇED report, a generation forecast, emissions measurement, valuation or a technical conformity report. It examines the effect of these studies on permits, contracts and responsibilities.

The expert’s task, the information to be used, delivery of the report and responsibilities are determined. A technical opinion, a legal assessment and the decision of the competent authority are separate processes.

Our base and scope of work

Based in Antalya, energy projects across Türkiye

The location of the investment, the competent authority, the judicial or arbitral route and the conditions of representation are assessed separately in each file.

Legal services since 1999

Güneş & Güneş Law Firm was founded in Kemer on March 18, 1999 by Attorney Umut Güneş. With an institutional history of more than 27 years, and from its physical headquarters in Antalya since 2007, it organizes its services for energy projects in all 81 provinces of Türkiye in advisory work, licensing, administrative applications, litigation and arbitration.

The need for on-site review and local procedures is planned with regard to the rules of jurisdiction and procedure. The implementation and enforcement of decisions may also be included in the agreed scope of work.

Foreign investments connected with Türkiye

Energy transactions in Türkiye by investors resident abroad can be carried out through online consultation, secure document sharing and communication in Turkish, English, German and Russian.

The applicable law, international jurisdiction, arbitration, the use of foreign documents, apostille or certification, translation, service of documents abroad, and recognition and enforcement are examined according to the file.

When local procedures are required abroad

The selection of an authorized attorney or cooperating law firm in the relevant country, preliminary discussions on behalf of the client, the scope and contract of the work, the work plan, document flow, time limit monitoring and regular information are coordinated. Local representation is carried out by an attorney authorized in the relevant country; the fees, expenses and responsibilities for coordination and for local representation are determined separately.

The firm’s approach

The project as a whole and a clear scope of work

The matters of individual and corporate clients are handled with regard to the disciplines required and the characteristics of the file.

Joint assessment

The regulatory permit, corporate, contractual, financing, real property, zoning, environmental and dispute dimensions are addressed together.

Multidisciplinary work

A division of tasks and an information flow are established between the legal file and the reviews of technical, environmental and financial experts.

Clear options

The application, contract, transaction and dispute options are explained together with their conditions, cost elements and uncertainties.

Confidentiality and information

Information is used for the legal assessment and the agreed service. The work plan and important developments are shared with the client.

Scope of work and fees

Advisory work, licensing, contracts, due diligence, litigation and arbitration are identified as separate work items. The scope of the attorney’s fee, court fees, translation, local legal counsel, technical experts and other expenses is clarified and reflected in the service agreement.

Frequently asked questions

About Energy Law

The answers explain the general framework. The type of facility, the date of application, the contract and the relevant decision should be assessed together.

Which permits are required for an energy project?

The required permits vary according to the energy source, whether the activity is licensed or unlicensed, the capacity of the facility, its location and the nature of the land. EPDK procedures should be assessed together with the connection, zoning, construction, ÇED, environmental, forest, pasture, agricultural and business permits.

What is the difference between a pre-license and a generation license?

A pre-license is a preparatory period aimed at completing certain permits and project obligations required for a generation investment. A generation license, on the other hand, is the authorization to carry on the generation activity after the conditions envisaged in the legislation have been met. The specific conditions and periods should be examined on the basis of current legislation.

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Is unlicensed electricity generation possible for every project?

No. Unlicensed generation depends on the person, facility, connection and consumption relationship conditions specified in the legislation. The project’s self-consumption purpose, its link to the consumption facility, the connection capacity and the offsetting model are examined together.

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Which documents should be reviewed when acquiring an energy project?

In addition to the company records, the licenses, permits, connection rights, land documents, zoning and ÇED status, principal project contracts, financing and security, incentives, technical progress, lawsuits and regulatory compliance should be reviewed.

What is a corporate power purchase agreement (PPA)?

A PPA is an agreement between a producer and a buyer on the sale of electricity for a specified period and within a commercial structure. Depending on whether the model is physical or financial, the provisions on price, volume, profile, imbalance, environmental attributes, security, change in legislation and termination differ.

Is a separate license required for an energy storage project?

Whether the storage unit is stand-alone or integrated into a generation or consumption facility affects the legal structure. The license, connection and market participation conditions should be assessed according to the project’s model and the current regulations.

Is a charging network license required to set up a charging station?

Operating a charging network is subject to a license; however, conditions such as the legal relationship under which the station will be operated, the certificate and the network connection are assessed separately. Use of the property, electricity connection, payment, data and consumer processes should also be regulated in the contract.

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Does a ÇED decision complete all the permits of an energy investment?

No. A ÇED decision is one part of the environmental assessment process. The license, connection, land, zoning, construction, forest, pasture, agricultural and other sector-specific permits may also need to be completed separately.

Can an action be filed against an EPDK decision?

Depending on the nature of the act, administrative application and judicial routes may be assessed. The date of notification, the court with subject-matter and territorial jurisdiction, the time limit for filing the action and the need for a stay of execution should be examined without delay.

Can energy disputes be resolved through arbitration?

Commercial energy disputes can be resolved through arbitration if the parties have a valid arbitration agreement and the dispute is arbitrable. For matters with an administrative act or public law dimension, a separate review of subject-matter jurisdiction and arbitrability is required.

Are a carbon credit and YEK-G the same thing?

No. Although both are associated with environmental attributes, their legal bases, issuance conditions, tracking systems and the value they represent differ. The contract should state clearly which certificate or environmental attribute is being transferred.

Does an attorney prepare technical reports in an energy file?

The attorney handles legal review, contracts, permits, applications and dispute management. Engineering, generation forecast, valuation, environmental measurement and technical conformity reports are prepared by authorized experts; the legal consequences of these studies and their consistency with the contracts are assessed by the attorney.

Are all wind (RES) or solar (GES) permits now obtained from the Ministry?

No. The zoning and permit authorities within the scope of the July 24, 2026 regulation do not eliminate the other relevant permits. The official guide explains that the Ministry’s authority is not exclusive. The project’s license status, its existing applications, and its real property and sector-specific permits are examined separately.

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Does the new zoning regulation automatically transfer my previous application?

No. According to the official guide, a pending file does not pass to the Ministry automatically. If a new application is requested, the legal status of the existing file, the application procedure and the validity of the documents are assessed together.

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Is participating in YEKDEM the same as obtaining a YEK-G certificate?

No. YEKDEM is a support mechanism, whereas YEK-G is the certification system for the renewable source of electricity. Participation conditions, revenue and the transfer of environmental attributes are regulated separately. YEKA competitions are also a different investment model.

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Does the Türkiye ETS apply on the same date to all energy companies?

No conclusion can be drawn from a single company or sector label. Under the 2026 regulation, the activity, the facility category, cases outside the scope, the transition of the permit and the pilot decisions are assessed together. Dates announced during the draft period cannot be used in place of the definitive entry-into-force calendar.

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Is green taxonomy reporting immediately mandatory for all companies?

The reporting regime differs for financial institutions and for those carrying on other economic activities. A transition until January 1, 2029 is envisaged for financial institutions. Even so, taxonomy information or a report may be requested from a company in a financing transaction; the company’s role and the relevant regulatory rules should be examined.

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Is card payment at a charging station subject to the same condition everywhere?

The special condition dated July 1, 2026 relates, on highways under the responsibility of KGM, to at least one of the DC 50 kW and higher units at stations newly added to the network from this date. The payment, access and information provisions that apply at other stations are also examined separately.

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Is an EPDK review required in a share transfer of an energy company?

Depending on the activity, the license and the nature of the direct or indirect change of control, a permit, approval or notification may be required. Company law transactions, regulatory conditions and the competition notification are checked independently of one another.

Does a price increase automatically modify a PPA or EPC contract?

It does not automatically modify every contract. The price formula, adjustment, change in legislation, force majeure, notice and termination provisions are examined together with the applicable law. The effect on the financing and security documents is also assessed.

What is needed in a dispute over connection capacity or generation curtailment?

The application and connection documents, authority letters, the system use agreement, facility records, curtailment notices and the bases of the loss calculation are useful. A technical cause and legal liability are not the same thing; the competent authority and the route of application are determined separately.

Is offsetting in unlicensed generation monthly for every facility?

No. The April 2, 2026 amendment and the provisions that enter into force on May 1, 2026 contain rules based on hourly offsetting. There is a monthly offsetting exception for facilities associated with residential subscriptions that have been entitled to a call letter since May 12, 2019. The facility’s legal basis, the call letter and the consumption relationship should be examined separately.

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How are energy transactions outside Türkiye carried out?

Legal work connected with Türkiye is coordinated, when necessary, with an attorney or cooperating law firm authorized in the relevant country. The authority for local representation, the scope, fees, information sharing and responsibilities are determined separately.

What should I share in the first consultation, and when does representation begin?

It is sufficient to state the type of project or facility, the province, the stage of the transaction, the issue you are facing and the upcoming time limit. The sharing of sensitive documents is planned separately. A consultation request by itself is not the acceptance of the matter or the start of representation; the service scope and the necessary authorization are completed.

Areas assessed together

Related practice areas

Coordination with other legal practice areas is established according to the needs of the energy project.

Related sectors

Sources and information

Basic legislation and official sources

Laws, the current legislation of the relevant authorities, project-specific decisions and transitional provisions are assessed together.

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Legal information note

This page is general information; it does not constitute a legal opinion, or a commitment as to a permit, capacity, incentive, financing or outcome, for a specific project. Energy legislation, license fees, sanction amounts and application calendars may change. Each transaction is assessed separately with the current text and the conditions of the specific case.

Content preparation date: October 4, 2026.

Legal consultation

Briefly describe your energy project or dispute.

You may request a consultation on an investment, license, connection, land, ÇED, contract, financing, charging network, regulatory compliance or dispute.

State the type of project, the province, the current stage and the upcoming time limit. For a time-limited step, also preserve your own application calendar.

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