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Environmental & Climate Law

Is your plant legally ready for the new climate regime?

From EIA to environmental permits, from waste management to carbon regulation — environmental law now touches every decision your plant makes. We simplify that landscape through a lawyer's lens: structuring your obligations in advance, and taking over your defence when a penalty is served. In English, Turkish and Russian.

Turkish ETS CBAM Permits & Licenses Penalties & Disputes
Who It's For

At your side in two situations.

Steel, cement, aluminium, fertilisers, chemicals, glass — for energy-intensive industry, climate regulation is no longer a CSR heading but a balance-sheet item. The Climate Law brought ETS obligations; CBAM's definitive period has begun for EU-bound exports; environmental inspections have intensified.

We manage this landscape from both directions: building your compliance programme before obligations crystallise, and taking over your defence when a sanction arrives. One principle governs both: in a field ruled by deadlines, whoever is late loses bargaining power.

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Situation 1 · Proactive
Compliance Programme

ETS scope analysis, greenhouse-gas emission permit, monitoring-reporting-verification (MRV) infrastructure, CBAM data readiness, completion of environmental permits and licenses, TSRS reporting: your obligation calendar is mapped, every item is closed, and you become audit-ready.

Situation 2 · Reactive
Enforcement & Dispute Defence

Once a penalty is served, the clock runs: an annulment action before the administrative court within 30 days, a stay-of-execution request, urgent applications against operation-suspension orders, and a defence strategy that starts at the inspection report stage.

Service Flow

The compliance journey in five steps

01
Obligation Screening

Is your installation in ETS scope, are your products in a CBAM sector, are current permits complete? Your obligation map comes out of the first round.

02
Gap Analysis & Roadmap

Current state versus what the legislation requires; gaps reported with priority, timeline and cost dimensions.

03
Permits & MRV Infrastructure

Greenhouse-gas emission permit, monitoring plan, environmental permit and license applications — prepared and concluded by our team.

04
Reporting & Verification

Annual emission reports, the verifier process, CBAM data sharing and TSRS reporting, managed period by period.

05
Audits & Disputes

Audit preparation and attendance; in case of sanctions, objections, annulment actions and stay-of-execution proceedings.

Scope of Services

From the stack to the balance sheet, one counsel

From emission permits to export data, from waste licenses to annulment actions.

01

Turkish ETS & Climate Law Compliance

Scope analysis under Law No. 7552, greenhouse-gas emission permit, allowance strategy and 2026–27 pilot-phase planning.

02

Monitoring, Reporting, Verification (MRV)

Preparation and approval of the monitoring plan, annual emission reports, legal management of verifier processes.

03

CBAM Exporter Compliance

Embedded-emission calculation and verification, data-sharing agreements with EU importers, management of default-value risk.

04

Environmental Permits & Licenses

Emission, wastewater, noise and soil-contamination regimes; provisional activity certificates, renewals and e-permit process management.

05

Challenging Fines & Annulment Actions

Annulment actions against environmental fines within 30 days, stays of execution, urgent applications against operation suspensions.

06

Waste Management & Circular Economy

Waste-producer obligations, hazardous waste and chemicals management (KKDİK), disposal contracts, zero-waste and circular-economy practices.

07

Sustainability Reporting

TSRS scope assessment, climate-risk disclosures, interaction with the EU CSRD and the legality of green claims.

08

Carbon Markets & Certificates

Voluntary carbon credit transactions, YEK-G / I-REC procurement, carbon-pricing strategy and contract infrastructure.

09

Environmental Due Diligence

Environmental risk review and compliance audits in plant acquisitions and mergers, historical contamination liability, warranty and indemnity clauses.

10

EIA Processes & Decisions

Legal management of project description files and full EIA reports; advisory on "EIA positive / not required" decisions and representation in litigation over them.

11

Environmental Liability & Damages

Civil liability arising from environmental harm, damages disputes, nuisance-based claims and insurance relations.

12

Compliance & Legal Risk Analysis

Holistic screening of your operations against environmental legislation, a legal risk map and a corrective action plan.

Regulatory Framework

The legislation binding industry, at a glance

The key statutes and regulations that set your compliance calendar.

30 days
Deadline to challenge an environmental fine (Environmental Law, Art. 25)
6 sectors
CBAM scope: iron & steel, cement, aluminium, fertilisers, electricity, hydrogen
3 yrs
Transition period for the greenhouse-gas emission permit (Climate Law No. 7552)
2026–27
Pilot phase of the Turkish Emissions Trading System
Law No. 2872Environmental Law

The foundational statute: the pollution ban, the permit regime and administrative sanctions. Annulment actions against fines must be filed before the administrative court within 30 days of notification; filing does not automatically suspend collection.

Law No. 7552Climate Law

Türkiye's first climate statute (Official Gazette, 9 July 2025): established the Emissions Trading System. Greenhouse-gas emission permits (3-year transition) and MRV obligations for in-scope operators; pilot phase 2026–2027.

Secondary RegulationGreenhouse Gas Monitoring Regulation

The existing MRV regime: monitoring plans, annual emission reports and verification obligations. It forms the data backbone of the transition to the ETS; ETS secondary legislation is being built on top of it.

EU Regulation 2023/956Carbon Border Adjustment Mechanism (CBAM)

The definitive period started on 1 January 2026: EU importers purchase CBAM certificates for the embedded emissions of covered products (first surrender due 30 September 2027). Supplying verified emissions data is a commercial necessity for Turkish exporters.

Environmental LawEnvironmental Permit & License Regulation

The procedure for provisional activity certificates and environmental permits and licenses covering emissions, wastewater, noise and waste processing; sanctions for unpermitted operation.

Environmental LawWaste Management & Zero Waste Regulations

Waste-producer obligations, the hazardous-waste regime, the transport-disposal chain and the zero-waste certification system.

Environmental LawEIA Regulation

Environmental impact assessment for capacity increases, modernisation and new plant investments; "EIA positive / not required" decisions and litigation against them.

POA RegulationTurkish Sustainability Reporting Standards (TSRS)

Mandatory sustainability reporting for large undertakings exceeding the thresholds: disclosure of climate risks and emissions alongside financial reports.

Law No. 5326Misdemeanours Law

The general procedure for administrative sanctions: collection of three quarters of the fine on early payment (a 25% discount) with the right to sue preserved.

Law No. 2577Administrative Procedure Law

The procedural framework for annulment actions and stays of execution: establishing irreparable harm and manifest unlawfulness.

This table is for general information; the legislation is frequently amended. The current framework applicable to your business is set out in detail in the compliance report. Last updated: July 2026.

Served with a Penalty?

The clock is running: 30 days

The most common mistake with environmental fines is waiting. The deadline to sue is 30 days from notification and it is preclusive; moreover, filing the action does not automatically stop collection. A properly structured application targets three things at once: annulment of the fine, a stay of execution, and uninterrupted operation of your plant.

Our View

"The defence begins when the inspection report is signed — not when the statement of claim is filed."

01
Inspection & Report Stage
Protecting your rights during the inspection and at the report stage; getting technical objections on the record from the outset lays the foundation of the later lawsuit.
02
Annulment Action — 30 Days
Under Article 25 of the Environmental Law, an annulment action before the administrative court within 30 days of notification: review on competence, procedure, measurement and proportionality grounds.
03
Stay of Execution
Because filing does not automatically stop collection, a stay of execution is requested separately by establishing irreparable harm.
04
Payment Strategy
Early payment earns a 25% reduction while the right to sue is preserved; cash flow and litigation risk are weighed together before deciding.
05
Urgent Applications Against Suspension
With partial or full operation-suspension orders, lost production grows daily; the urgent stay application and the remediation plan run in parallel.
06
Recurrence & Compliance Repair
Fines multiply on repeat violations. A compliance-repair programme run alongside the defence prevents you from facing the same sanction again.
Technology

The Law 4.0 touch

Environmental & Climate Advisory Powered by Our Own Tools

Climate regulation in Türkiye is taking shape at a pace measured in weeks: secondary regulations, drafts, EU implementing acts. Thanks to our in-house tools, your compliance programme is updated the day the legislation changes.

✦
Live Legislation Monitoring
Our own legislation & case-law engine (13,844 laws · 11 million+ court decisions) tracks every change in environmental and climate secondary regulation as it happens.
✦
AI-Assisted Analysis
Obligation screenings and gap analyses are prepared with our AI-assisted tools; every output is finalised under attorney review.
✦
Transparency via LexiDesk
Track the status of permit applications, court files and the reporting calendar on our client portal, 24/7.
✦
Reporting in Three Languages
Compliance reports are delivered in English, Turkish and Russian — you and your EU importer or foreign partner work from the same document.
KS Law · ETS Compliance Board
Steel Plant — Compliance Programme
Obligation status · live
14
Items closed
2
Deadlines near
1
Pending verification
ETS
CBAM
Permit
Frequently Asked Questions

What industrialists ask us most

How do I challenge an environmental fine in Türkiye, and what is the deadline?

Under Article 25 of the Environmental Law No. 2872, an annulment action against the sanction must be filed before the administrative court within 30 days of notification; the deadline is preclusive. The critical point: filing the action does not automatically suspend collection — a stay of execution must be requested and justified separately.

Is there a discount for early payment, and do I keep my right to sue?

Yes. Under Article 17 of the Misdemeanours Law, if payment is made before applying to legal remedies, three quarters of the fine is collected (a 25% discount) — and payment does not extinguish your right to sue. Cash flow, interest risk and the prospects of the case are weighed together to set the payment strategy.

Which businesses does the Turkish Climate Law and ETS cover?

Climate Law No. 7552 brings installations exceeding the thresholds in secondary legislation into the ETS; energy-intensive sectors — power generation, iron and steel, cement, refining, chemicals, fertilisers — come first. In-scope operators must obtain a greenhouse-gas emission permit within 3 years of the Law's entry into force. Whether your installation is in scope is the first question of the obligation screening.

What should I do during the ETS pilot phase (2026–2027)?

No allowance trading takes place in the pilot phase; the system is tested and penalties are applied at reduced rates. It is not an exemption but a preparation window: use it to have the monitoring plan approved, build the MRV infrastructure and prepare the allowance strategy. A gap left open in the pilot returns as cost in the definitive period.

How does CBAM affect Turkish exporters?

CBAM's definitive period started on 1 January 2026. In iron and steel, cement, aluminium, fertilisers, electricity and hydrogen, your EU importer must purchase CBAM certificates for your product's embedded emissions; the first surrender is due 30 September 2027. Importers will demand verified emissions data — a supplier who cannot provide it risks dropping off the order list.

What is the "default value" risk under CBAM?

If actual, verified emissions data cannot be provided, the EU applies high, pre-set default emission values to the product. That is a direct price disadvantage against competitors who produce cleaner — or can document their data. MRV infrastructure is therefore a commercial necessity before it is an environmental obligation.

Who must file TSRS sustainability reports?

The Turkish Sustainability Reporting Standards (TSRS) are mandatory for large undertakings exceeding the thresholds set by the Public Oversight Authority and for certain institutions. Reports must disclose climate risks, targets and emissions alongside financial statements and must be consistent with your ETS/CBAM data — inconsistent disclosure creates both regulatory and reputational risk.

What are the consequences of operating without an environmental permit?

Unpermitted or unlicensed operation can lead not only to administrative fines but to partial or full suspension of operations — lost production usually costs more than the fine itself. Closing gaps before the inspector arrives is always cheaper than defending afterwards; that is the entire rationale of the compliance programme.

The answers in this section are for general information only and do not constitute legal advice. For an assessment specific to your business, contact us.

First Step

Don't wait for the audit; set the calendar yourself.

Tell us your plant's sector, your EU export exposure and any sanction you have been served with; we will start the obligation screening. If a penalty has been notified, state the notification date — the 30-day litigation deadline runs from it.

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