Penalties Under Climate Law No. 7552

The administrative sanctions of Climate Law No. 7552 are brought together in Article 14 of the Law, published in the Official Gazette dated 9 July 2025, No. 32951. The article separately lists breaches of the rules on monitoring greenhouse gas emissions, ozone-depleting substances, fluorinated greenhouse gases and the Emissions Trading System (ETS). The amounts below are those written in the text of the Law; the amounts applicable in 2026 are set by the separately published Communiqué 2026/1 and are not given on this page.

What are the penalties for emission reports and permits?

Those who do not submit a verified greenhouse gas emissions report on time face an administrative fine of TL 500,000 to TL 5,000,000; for ETS enterprises the fine is doubled (Article 14(1)). If an ETS report is not submitted on time, transactions on allowances in the registry accounts, other than delivery of the surrender obligation, are blocked; the block is lifted when the report is submitted, but this does not prevent the fine from being applied (Article 14(4)(a)).

ETS enterprises operating without a greenhouse gas emission permit, or with an expired or cancelled one, are fined TL 5 per tonne of carbon dioxide equivalent in the highest report submitted in the last five years if they have a verified annual report, and TL 1,000,000 to TL 10,000,000 if they do not (Article 14(4)(b)).

What applies to ozone-depleting substances and fluorinated gases?

Those who use, import, trade in or place on the market ozone-depleting substances are fined TL 2,500,000; natural and legal persons who maintain, repair or service products or equipment containing them are fined TL 250,000; and those who fail to comply with labelling rules are fined TL 120,000 (Article 14(2)).

Those who use, trade in or place fluorinated greenhouse gases on the market are fined TL 2,500,000 and are refused a Hydrofluorocarbon Control Certificate for three to six months. Those who import hydrofluorocarbons without a quota or above their quota are fined TL 1,000,000 and their quota is reduced the following year. Non-compliance with labelling rules, failing to enter notifications and reports into the database on time or to update data, and interfering with equipment that contains or relies on fluorinated gases carry a fine of TL 120,000 each (Article 14(3)).

How is a failure to surrender allowances sanctioned?

ETS enterprises must surrender allowances corresponding to their verified annual emissions. For each allowance not surrendered on time, an administrative fine equal to twice the higher of the weighted average primary-market and secondary-market allowance prices for the last three months of the year to which the report relates is imposed. In addition, an enterprise that fails for three consecutive years to meet at least 80 percent of its surrender obligation has its emission permit cancelled and is refused a new permit for three to six months (Article 14(4)(c) and (ç)). Project owners that do not meet the registration duty for carbon credit projects, and those who fail to provide information, documents or data or who make misleading statements, face fines of TL 120,000 and TL 170,000 respectively (Article 14(5) and (6)).

How do the fines increase and what limits apply?

If the same act is repeated within three years of the fine being served, the fine is increased by one times on the first repetition and by two times on the second and later repetitions (Article 14(9)). The Ministry may give a one-off period of up to one year to correct a breach; if it is not corrected by then, the activity is suspended in part or in full. Giving time or suspending the activity does not prevent the fine from being applied (Article 14(10)). The fine for a single act cannot exceed TL 50,000,000 (Article 14(11)). During the pilot period before the ETS is fully implemented, fines for breaches of these obligations are applied with an 80 percent reduction (Provisional Article 1).

Sanction decisions are issued by the Climate Change Presidency; an action may be brought against the Presidency before the administrative court, and filing it does not suspend collection (Articles 15 and 16). Fifty percent of the fines under the Law is recorded as special revenue (Article 12).

What should be checked in practice?

Businesses should first establish whether they fall within the ETS under the rules to be set by regulation, because many penalties differ depending on ETS coverage. Businesses that handle equipment containing refrigerant or other fluorinated gases through maintenance, service or trade should keep their labelling, quota and database notifications on record. For the 2026 amounts, Communiqué 2026/1 should be consulted.