The Three-Year Clock Is Running
When Climate Law 7552 took effect on 9 July 2025, it established the legal architecture for Türkiye's Emissions Trading System (TR-ETS) (Resmî Gazete, 2025). Under Provisional Article 1, installations that will fall within the ETS scope must obtain a greenhouse gas emission permit within three years of the law's entry into force — i.e., by July 2028. The Carbon Markets Board will define a pilot phase during which administrative penalties are reduced by 80%, but the underlying monitoring, reporting, and verification (MRV) obligations operate independently of that discount.
Three years sounds long. It isn't. Standing up MRV infrastructure — particularly for industrial groups with multiple installations — is not a "collect the data" project; it is an "operate an auditable data management system" project. Operators who have lived inside the EU ETS for more than a decade know how unforgiving that distinction can be.
The Skeleton of TR-ETS MRV
Article 9 of the law commits ETS-covered installations to annual surrender of allowances equal to verified greenhouse gas emissions. That makes MRV more than a reporting chore — it is the trigger for a direct financial obligation. Every reported tonne of CO₂ equivalent will require either an allowance or an offset.
Authority over the MRV process sits with the Climate Change Directorate (İklim Değişikliği Başkanlığı) under Article 10(c) of the law (Resmî Gazete, 2021). The detailed MRV procedures will arrive through secondary regulation, which is still in preparation. Until then, the reference architecture is readable from two sources: Türkiye's pilot experience under the 2014 voluntary Greenhouse Gas Monitoring and Reporting Regulation, and the EU ETS Monitoring and Reporting Regulation — Commission Implementing Regulation (EU) 2018/2066. The EU MRR introduces four building blocks that TR-ETS regulation is highly likely to mirror:
- Installation categorisation: Category A (≤50,000 tCO₂e/year), Category B (50,001–500,000 tCO₂e), and Category C (>500,000 tCO₂e) — driving minimum tier requirements.
- Tier structure: Per-source-stream uncertainty thresholds for activity data and emission factors. Fall-back methodologies must stay below 2.5% overall uncertainty for Category C installations.
- Monitoring plan: The competent-authority-approved master document covering installation boundaries, source streams, emission sources, measuring equipment, data-flow procedures, and control activities. It functions as the operating contract of the entire system.
- Data flow and control system: Written data-flow procedures, a risk-based control system, QA of measurement equipment and IT, segregation of duties, internal reviews, and corrective action.
Practically: TR-ETS shares the conceptual logic of ISO 14064-1:2018 organization-level GHG inventories, but enforces much tighter installation-level categorisation, uncertainty, and verification rules (ISO, 2018). Companies that built corporate inventories for TSRS reporting in 2024 will still need to retrofit their existing inventory infrastructure to installation-level granularity and lower uncertainty thresholds once they fall within ETS scope.
Five Readiness Questions
Sustainability and finance-control teams should produce concrete answers to these questions before the pilot phase begins:
1. Are your installation boundaries clearly defined? Most manufacturers build their corporate GHG inventory under operational control. ETS uses an installation-level definition tied to the operating permit. Two emission permits on the same campus must be reported separately; shared utilities (boilers, cogeneration) must be allocated between installations with documented rationale.
2. Can you enumerate your source streams? Every fuel, every raw material, every process output is a source stream. A steel plant tracks coal, natural gas, coking coal, lime, and alloying agents — each as a separate source stream. Whether a stream is "major", "minor", or "de minimis" drives the required measurement/calculation tier and must be decided early.
3. Is there an audit trail behind activity data? Natural gas meter readings, weighbridge tickets, lab analyses, invoice data — every data point must trace back to a source, a measuring device, a calibration record, and a human approval. The EU MRR requires all monitoring data to be retained for at least 10 years; TR-ETS is expected to impose a comparable retention obligation.
4. Is emission factor management an active process? National emission factors, supplier-specific factors, laboratory analyses — the choice of factor per source stream must be stated in the monitoring plan. Factor changes (supplier switches, updates to national inventory factors) trigger monitoring plan revisions, which in turn require competent-authority notification or approval.
5. Are you third-party verification-ready? Annual emissions reports cannot be submitted without limited or reasonable assurance from an accredited verifier. Verifiers need access to a year's worth of organised evidence: monitoring plan, data flow procedures, control records, calibration certificates, invoice samples. For teams going through verification for the first time, a "dress rehearsal" verification is one of the best preparation moves available.
Penalties Stay Sharp Even in the Pilot
Administrative penalties under Article 14 are significant for ETS-covered installations: failure to submit a verified emissions report on time carries a doubled penalty for ETS installations — TRY 1 million to TRY 10 million. Failure to surrender allowances generates a penalty per missing allowance equal to twice the higher of the last three months' primary and secondary market weighted-average prices. Three consecutive years of meeting less than 80% of surrender obligations triggers revocation of the emission permit and a 3–6 month no-reissue period (Resmî Gazete, 2025).
The 80% reduction during the pilot phase tempers these numbers but does not lift the permit revocation tool. Using the pilot phase to stress-test and institutionalise MRV infrastructure — rather than as a grace period — is the only way to avoid losing remediation runway when the full phase begins.
What This Means for Your Team
TR-ETS MRV readiness is not a one-time project. It is a recurring cycle at the same operational tempo as financial reporting. Building installation-level, source-stream-grained, audit-ready data systems; bringing finance, verifier, and senior management into the inventory loop; and embedding monitoring plan revisions into governance workflows — that is the underlying infrastructure.
Enterprise platforms that centralise multi-installation inventory management, track monitoring plan versions, and store data flow controls in an auditable form are the same architectures EU ETS verifiers cite as the strongest control environments.
Action Item: Complete an MRV gap analysis for every prospective ETS installation by year-end. Installation categorisation, source-stream inventory, and a data-ownership matrix are the minimum outputs.
To discuss how MRV infrastructure is built for multi-installation operators, request a demo from Azalt.