Turkey amended its Environmental Management Services Regulation with immediate effect on 6 October 2026. The change is relevant to operators covered by the Environmental Permit and Licence Regulation and to investors reviewing the ongoing compliance costs of a Turkish facility. It introduces explicit minimum monthly service time, changes the minimum-fee formula, tightens reporting of breaches and sets transition dates for existing consultancy contracts and firms. It does not impose the same obligation on every company in Turkey: the first check is whether the facility falls in Annex 1 or Annex 2 of the permit-and-licence rules, or has voluntarily contracted for the service.
Minimum monthly service time is now explicit
Facilities in Annex 1 must receive environmental-management services for at least two business days per month. Annex 2 facilities must receive at least one business day per month. A business outside those lists that chooses to take the service is also subject to at least one business day. The Ministry may adjust these periods after considering pollution risk and capacity, under procedures it will publish separately.
The minimum fee formula has changed
For contracts signed while the new rule is in force, the monthly floor is calculated from the net minimum wage, excluding VAT: three quarters for Annex 1 facilities and one half for Annex 2 facilities. The formula also adds 5% of the Ministry's unit price for each environmental permit or licence subject recorded for the facility. The text therefore creates a floor, not a universal final invoice; the actual amount can be higher and depends on the facility's permits and contract scope.
Existing contracts face a 1 January 2027 checkpoint
Contracts already in force before the amendment must be renewed on the new minimum-tariff basis by 1 January 2027. Renewal is not required where the existing fee already equals or exceeds the new minimum. Environmental consultancy firms that already held a qualification certificate before the change must also meet the new professional-office registration requirement from 1 January 2027.
Reporting duties and sanctions are clearer
The amendment separates serious permit-related breaches from other non-compliance. Consultancy firms must record identified breaches and notify the competent authority where a business does not begin the formal corrective application within 30 days. Other non-compliance that remains unresolved for 90 days must be reported within the following 10 days. The regulation also expressly links failure to obtain required environmental-management services, and certain failures to provide records, to administrative fines under the Environmental Law.
What a foreign investor should review now
Ask the Turkish operating company to confirm the facility's Annex 1 or Annex 2 status, current environmental permit and licence subjects, consultancy contract price, monthly visit schedule and corrective-action log. Budget models for acquisitions, factories, logistics sites and other regulated facilities should be checked against the revised fee floor. The regulation took effect on publication, but classification and penalty exposure depend on the specific facility; transaction documents should be reviewed by Turkish environmental and legal advisers before relying on a general summary.
Official Gazette — original Environmental Management Services Regulation, 1 November 2022 →