Türkiye Green Taxonomy Regulation Published
The Türkiye Green Taxonomy Regulation (the “Regulation”) was published by the Ministry of Environment, Urbanisation and Climate Change in the Official Gazette dated 24 September 2026 and numbered 33380, and entered into force on the same date. The Regulation sets out the procedures and principles of the Türkiye Green Taxonomy with a view to classifying economic activities aligned with sustainable development goals, encouraging the flow of finance towards sustainable investments and preventing “greenwashing”.
The Regulation is largely modelled on the EU Taxonomy Regulation (Regulation (EU) 2020/852); its six environmental objectives and the core conditions for an economic activity to qualify as environmentally sustainable are substantially aligned with those of the EU framework.
The key changes introduced by the Regulation are summarised below.
1. GENERAL PRINCIPLES
One of the novelties introduced by the Regulation is that the concept of “greenwashing” has, for the first time, been expressly defined under Turkish legislation. Article 1 of the Regulation expressly lists the prevention of greenwashing in the market among the objectives of the Regulation.
Pursuant to sub-paragraph (z) of Article 4 of the Regulation, greenwashing is defined as “the deceptive use of public relations, financing, advertising or marketing methods to create the perception that the products or services of an institution, organisation or undertaking make a substantial contribution to one or more of the environmental objectives, do not cause significant harm to the other environmental objectives and comply with minimum social safeguards”.
Furthermore, under the Regulation, the activities listed in Annex 1 qualify as “eligible economic activities”. Annex 1 lists the economic activities falling within the scope of the taxonomy separately for each of the six environmental objectives, and the same activity may appear under more than one objective. The list covers a wide range of sectors, including forestry, manufacturing, energy, water supply and waste management, transport, construction and real estate, information and communication, professional and technical activities, finance and insurance, agriculture, and tourism and accommodation. However, the inclusion of an activity in Annex 1 does not in itself mean that the activity is environmentally sustainable or taxonomy-aligned. For an activity to qualify as an “aligned economic activity”, it must meet the relevant technical screening criteria and satisfy all of the conditions set out in the Regulation.
Accordingly, for an eligible economic activity listed in Annex 1 to qualify as an aligned economic activity, it must make a substantial contribution to at least one of the environmental objectives, cause no significant harm to any of the other environmental objectives and comply with minimum social safeguards. As these three conditions must be met cumulatively, the mere fact that an activity, for example, reduces greenhouse gas emissions or uses renewable energy will not be sufficient for it to be treated as taxonomy-aligned without a separate assessment of its impact on the other environmental objectives and of its compliance with the social safeguards.
2. ENVIRONMENTAL OBJECTIVES
The Regulation sets out six environmental objectives: i) reduction of greenhouse gas emissions, ii) adaptation to climate change, iii) sustainable use and protection of water and marine resources, iv) transition to a circular economy, v) pollution prevention and control, and vi) protection and restoration of biodiversity and ecosystems.
Accordingly, for an economic activity to be considered taxonomy-aligned, it must make a substantial contribution to at least one of the environmental objectives and cause no significant harm to any of the other environmental objectives. In this respect, the assessment of activities under the taxonomy will take into account whether they meet the substantial contribution criteria and the do no significant harm criteria set out in the technical screening criteria for the relevant environmental objective.
In addition, the minimum social safeguards have been framed to cover compliance with the principles set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, the Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises, the United Nations Guiding Principles on Business and Human Rights, and national labour and social security legislation. The taxonomy assessment will therefore rely not only on environmental performance indicators but also on companies’ human rights and employment policies and practices.
3. TECHNICAL SCREENING CRITERIA
Whether economic activities contribute to the environmental objectives and whether they cause significant harm to the other objectives will be assessed on the basis of technical screening criteria to be determined by the Climate Change Directorate (the “Directorate”). These criteria are intended to be, as far as possible, science-based, quantitative, verifiable and easy to use.
The criteria will take into account the short- and long-term impacts of activities, their life cycle, carbon footprint, the applicable legislation and sector-specific conditions, and will be updated regularly. Updated criteria will be published by 15 December each year and will apply from the following year.
The Regulation also makes clear that production activities using solid fossil fuels will not be regarded as environmentally sustainable activities under the technical screening criteria.
4. REPORTING OBLIGATIONS
Under the Regulation, the key performance indicators cover the proportion of turnover, capital expenditure and operating expenditure derived from taxonomy-eligible or taxonomy-aligned products and services. For financial institutions, additional ratios reflecting environmental sustainability and contribution to the environmental objectives will also be calculated.
Companies carrying out at least one of the eligible economic activities listed in the annex to the Regulation may report on a voluntary basis. By contrast, a reporting obligation is envisaged for entities qualifying as financial institutions, namely banks, investment firms, investment trusts, portfolio management companies, insurance companies, reinsurance companies and pension companies. The reporting procedures and principles for these institutions will be determined by the relevant regulatory authorities.
Reports must be uploaded to the Online Taxonomy Management System by the end of the sixth month following the end of the relevant financial reporting period, and reports uploaded to the system will, as a rule, be publicly available. Where the relevant ratio for turnover, capital expenditure or operating expenditure is below 10%, the relevant indicator may be excluded from the report.
5. TRANSITION PERIOD FOR FINANCIAL INSTITUTIONS
A transition period until 1 January 2029 has been granted to financial institutions subject to mandatory reporting in respect of their reporting obligations under the Regulation. Until that date, mandatory taxonomy reporting will not apply to banks, investment firms, investment trusts, portfolio management companies, insurance companies, reinsurance companies and pension companies.
Moreover, financial institutions will be entitled to request taxonomy data and reports from companies carrying out eligible economic activities for the purposes of their own reporting needs. Financial institutions may therefore request taxonomy data from their customers in the context of lending and investment relationships in order to calculate their own ratios, and reporting may, in practice, become a necessity for the real sector as well.
6. ADMINISTRATIVE SANCTIONS
Under the Regulation, reporting entities that fail to comply with their obligation to provide the required notifications, information and documents will be subject to administrative fines pursuant to paragraphs six, nine and eleven of Article 14 of Climate Law No. 7552. Accordingly, an administrative fine of TRY 213,333 will be imposed on those failing to comply with this obligation under the 2026 tariff. If the act giving rise to the fine is repeated within three years of the notification of the fine, the fine will be increased by one-fold for the first repetition and by two-fold for the second and subsequent repetitions. The administrative fine imposed for each act may not exceed TRY 62,745,000 for 2026. These amounts are updated annually by the revaluation rate.
CONCLUSION
The Regulation introduces a national classification system for determining whether economic activities are environmentally sustainable and expressly defines the concept of greenwashing at the level of legislation.
The Regulation imposes a mandatory reporting obligation only on financial institutions, and only as of 1 January 2029. However, financial institutions are expected to request taxonomy data from their customers in the context of lending and investment relationships in order to carry out their own reporting. Companies carrying out the activities listed in Annex 1 are therefore also expected to be affected by the Regulation in terms of access to finance, investor and customer demands, and their environmental claims.
Against this background, it is important for companies to map their activities against Annex 1, build the financial and environmental data infrastructure required for taxonomy reporting, and review the environmental claims relating to their products and services in light of the definition of greenwashing. The practical impact of the Regulation will become clearer with the technical screening criteria to be published by the Directorate and the secondary legislation to be issued by the Banking Regulation and Supervision Agency, the Capital Markets Board and the Insurance and Private Pension Regulation and Supervision Agency, and we recommend that these developments be closely monitored.
