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Climate Law No. 7552 and the Green Transformation Support Program: What Foreign Investors Need to Know

A Guide for Foreign Investors on Climate Law No. 7552 and the Green Transformation Initiative

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Climate Law No. 7552 and the Green Transformation Support Program: What Foreign Investors Need to Know
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I’m Evren ozmen, a CPA based in Istanbul, advising remote workers, freelancers, and international founders on Turkish tax and cross-border structuring. I focus on practical tax strategies around: 100% service export income deduction Tax residency in Turkey Company formation for foreigners Remote work and international income I break down complex tax rules into clear, actionable guidance — without losing the legal and compliance reality behind them. info@ozmconsultancy.com 🇹🇷 Türkiye genelinde; yazılım ve dijital ürün geliştiren şirketler, yurt dışına uzaktan hizmet sunan profesyoneller, Teknopark firmaları, oyun stüdyoları ve mobil uygulama şirketlerine Türkçe ve İngilizce mali ve vergisel danışmanlık hizmetleri sunuyoruz. 📘 Insights & Publications: https://medium.com/@evrenozmen 📩 For Online Tax Advisory & Accounting Services/Danışmanlık-Mali Müşavirlik Hizmetleri: info@ozmconsultancy.com

Climate Law No. 7552 and the Green Transformation Support Program: What Foreign Investors Need to Know

Introduction

On July 9, 2025, Turkey took a decisive step in aligning with its 2053 Net Zero Emission target and its Paris Agreement commitments by enacting Climate Law No. 7552 and amending the Green Transformation Support Program Implementation Principles. This law is not only a tool for environmental transformation but also a defensive mechanism against the EU Carbon Border Adjustment Mechanism (CBAM), ensuring carbon revenues remain within Turkey while mitigating the financial burdens CBAM would place on Turkish exporters.

This premium, SEO-optimized guide for investors, renewable energy firms, manufacturers, and ESG-conscious foreign entrepreneurs provides:

  • A clear breakdown of the Climate Law and Turkey’s Emission Trading System (ETS)

  • Strategic insights into CBAM readiness and carbon cost containment

  • Key application and compliance details of the updated Green Transformation Support Program

  • Practical analysis on how these frameworks will shape investment and operational decisions in Turkey


Table of Contents

  1. Climate Law No. 7552: Structure and Purpose

  2. Turkey’s Emission Trading System (ETS)

  3. CBAM, Carbon Revenue Retention, and Strategic Positioning

  4. Financing Green Transformation

  5. Green Transformation Support Program Updates

  6. Practical Considerations for Investors

  7. Conclusion


1. Climate Law No. 7552: Structure and Purpose

Climate Law No. 7552 positions Turkey on the path to its 2053 Net Zero goals, with a central focus on creating a domestic Emission Trading System (ETS) aligned with global carbon markets.

Key elements include:

  • Establishment of a Climate Change Directorate under the Ministry of Environment for technical and administrative operations.

  • Strategic decision-making centralized under a Carbon Market Board composed of senior representatives from economic ministries and regulatory authorities.

  • Enforcement mechanisms with double-market price penalties for companies failing to meet annual emission obligations, ensuring continuous market activity.

These provisions combine economic pragmatism with regulatory clarity, making the law a backbone for Turkey’s green market transition.


2. Turkey’s Emission Trading System (ETS)

How It Works

Turkey’s ETS follows a cap-and-trade model, where:

  • Annual emission caps are set for high-emission sectors.

  • Emission allowances are allocated to companies, who can trade surplus allowances if they reduce emissions or purchase additional ones if they exceed caps.

Market Management

  • Operated by EPİAŞ (Turkey’s Energy Markets Operator).

  • Free allowances will be granted to sectors vulnerable to international competition, while others will be auctioned.

  • A pilot phase will run with 80% penalty reductions to allow industrial adaptation before full implementation.


3. CBAM, Carbon Revenue Retention, and Strategic Positioning

The EU’s CBAM imposes additional carbon costs on imported carbon-intensive products.

Turkey’s domestic ETS enables:

  • Offsetting ETS payments against CBAM obligations.

  • Retention of carbon revenues within Turkey, financing local green transition investments instead of transferring funds to the EU.

This structure is designed to shield Turkish exporters while accelerating domestic decarbonization and industrial competitiveness.


4. Financing Green Transformation

Revenue Allocation:

  • ETS auction revenues will be ring-fenced for green transformation and climate action projects, prohibiting cross-budget diversions.

Just Transition Funding:

  • Up to 10% of revenues will support workers and communities affected by the green transition, enhancing social legitimacy.

Green Workforce Development:

  • The Ministry of Education and universities will update curricula to prepare a workforce skilled in green technologies and sustainable practices.

5. Green Transformation Support Program Updates

The amended regulation aims to facilitate low-carbon, resource-efficient production compatible with circular economy principles.

Key Requirements:

  • Roadmap Report: Companies must prepare a facility-specific roadmap aligned with ministry templates, projecting a minimum five-year green transformation strategy.

  • Green Transformation Team & Leader: Mandatory for each project, including an authorized leader for digital submissions and coordination.

Application Process:

  • Submissions via the online portal by the designated green transformation leader.

  • Only one active application per facility at a time.

  • Applications undergo formal review, correction windows, and eligibility filtering.

Scope and Supports:

  • Supports additional investments in existing facilities; greenfield investments and R&D projects are excluded.

  • Renewable energy (solar/wind) can be included in the project scope but excluded from incentive certificates.

  • Approved projects qualify for incentives under Decree No. 9903.

Monitoring, Revision, and Completion:

  • Progress tracked by ministry-appointed evaluators.

  • Approved revision requests processed through the General Directorate.

  • Projects failing to meet targets will lose "Green Transformation Center" status but may qualify under alternative incentive programs.


6. Practical Considerations for Investors

AspectImplications for Investors
ETS ImplementationCompliance planning required for emission-intensive industries, with opportunities for carbon credit trading.
CBAM ReadinessReduces risk of EU CBAM payments, preserving export competitiveness.
Funding OpportunitiesAccess to ring-fenced green funds for transformation projects.
Workforce PlanningEarly alignment with green workforce development can reduce HR and compliance costs.
Project StrategyFocusing on facility upgrades over new investments leverages incentive mechanisms effectively.

These mechanisms position Turkey as a forward-looking, ESG-aligned investment destination for manufacturers and renewable energy developers.


7. Conclusion

Climate Law No. 7552 and the Green Transformation Support Program are not merely compliance burdens but strategic opportunities for foreign investors in Turkey:

  • Align with Turkey’s Net Zero 2053 roadmap.

  • Gain a first-mover advantage in the carbon markets.

  • Offset CBAM liabilities.

  • Access dedicated funding for green upgrades.

  • Position your brand in line with global ESG trends.

If you are considering expanding your operations in Turkey or aligning your production with global green requirements while maximizing incentives, now is the time to act.


Call to Action

We assist foreign investors and manufacturers in designing and executing ETS compliance strategies, CBAM readiness assessments, and Green Transformation Program applications in Turkey.

Contact us to schedule a private, tailored consultation to:

  • Evaluate your eligibility for green transformation incentives.

  • Model your ETS exposure and trading strategy.

  • Structure your investment to align with upcoming Turkish climate regulations.

Prepare your operations for the future while maximizing your compliance advantage.

info@ozmconsultancy.com

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Evren Özmen CPA | Turkey Tax Advisor for Remote Workers, Digital Nomads & Foreign Companies

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