On 1 October 2026, Türkiye announced the publication of detailed rules for the pilot phase of its national emissions trading system (TR-ETS), which covers 2026 and 2027 emissions. The rules explain how installations define their sub-installations, how benchmarks are calculated, and how free allowances are determined.
The Directorate of Climate Change (DoCC) issued the Procedures and Principles for the TR-ETS Pilot Implementation Period, which turn the pilot design announced by the Carbon Market Board in September into operational requirements. The document builds on the regulation published in August and the Climate Law adopted in July 2025, and gives covered entities their first clear timeline for compliance obligations ahead of Türkiye’s first full implementation period.
First surrender deadline set for November 2028
Covered entities must surrender allowances for 2027 emissions by the last business day of November 2028. For 2026, entities only have to report their emissions, though they may make a voluntary payment for these emissions under the supplementary allowance pricing mechanism, for which the DoCC is still developing the methodology.
Allowances issued during the pilot phase cannot be carried into the first implementation period, and any unmet obligation for 2027 is added to the obligation for 2028, the first year of that period.
Free allocation set at 100%, flexibility limited for the pilot
The free allocation rate will be 100% for 2027 emissions. The regulation provides for banking and borrowing, but the Procedures and Principles do not apply them to the pilot phase. Offsets can be used only if the Board decides on their scope and limit.
Electricity benchmarks rely on historical data
Power plants will receive plant-specific benchmarks based on the weighted average of their emissions intensity over 2023-2027. They must therefore submit verified activity level reports for 2023-2025 by 30 June 2027. A sectoral correction factor will balance total allowance shortfalls and surpluses among power plants.
All covered installations, including power plants, must submit verified activity level reports for 2026 by 30 April 2027, and for 2027 by 30 April 2028. Accredited verifiers check the reports before submission. The DoCC will publish the pilot benchmarks in the National Allocation Plan after it receives the verified reports.
Benchmarks capped ahead of first full period
The first full implementation period will start with 2028 emissions and end with 2035 emissions, split into two sub-periods (2028–2030 and 2031–2035). Benchmarks determine the number of free allowances per unit of output and, because the cap is set ex-post, the overall cap. They cannot rise above recent levels. Through 2030, annual benchmarks for non-electricity sub-installations cannot exceed the average of the previous two years' values.
The Procedures and Principles also include the list of sub-installations and product benchmarks based on Production Communautaire (PRODCOM) codes, which classify manufactured products across the EU; the order for assigning emissions to sub-installations; and the requirements for monitoring methodology plans and activity level reports. They further cover verifier requirements and the calibration of measuring equipment.
Several decisions remain open, including whether offsets can be used in the pilot phase, the methodology for the supplementary allowance pricing mechanism, and the first National Allocation Plan. The DoCC is expected to issue further guidance ahead of the pilot phase’s first compliance deadlines to support implementation.
