

Energy Storage License Applications in Turkey: EMRA Requirements and Legal Process (2026)
Complete 2026 guide to energy storage license applications in Turkey. Learn about standalone storage facilities, storage-integrated solar and wind projects, EMRA preliminary licenses, generation and supply licenses, grid connection, permits, guarantees, foreign investment rules, and appeal remedies.
Electricity storage has become a central part of Turkey’s energy-transition strategy. Battery energy storage systems can support the integration of solar and wind generation, improve grid flexibility, reduce curtailment, provide balancing capacity, and create new commercial opportunities for energy investors.
For foreign investors, however, establishing an energy storage project in Turkey requires more than purchasing batteries and securing a site. The correct regulatory route depends on whether the storage facility will be:
Each structure may involve different licensing, amendment, grid-connection, metering, market-participation, and technical requirements.
Turkey’s principal storage framework is based on Electricity Market Law No. 6446, the Electricity Market Licensing Regulation, the Regulation on Storage Activities in the Electricity Market, the Electricity Grid Regulation, EMRA decisions, and technical criteria issued by the Turkish Electricity Transmission Corporation, commonly known as TEİAŞ.
As a general licensing principle, electricity generation requires a preliminary license followed by a generation license, unless the project falls within a statutory exemption. EMRA describes the preliminary license as the limited-term authorisation enabling a legal entity to obtain the permits, approvals, land rights, and similar authorisations necessary before construction and licensing.
This guide explains the 2026 legal framework, application routes, required documents, project-development obligations, and principal risks affecting foreign investors seeking to develop energy storage facilities in Turkey.
An electricity storage facility receives electrical energy from the grid or a generation facility, stores that energy in another form, and later converts it back into electricity for use or injection into the system.
The most common technology is battery energy storage, particularly lithium-ion systems. Other technologies may include:
The regulatory classification depends not only on the technology but also on the project’s connection point, ownership structure, associated license, and market purpose.
Foreign investors should identify the correct project model before preparing an EMRA application.
A storage unit may be physically and operationally integrated into a licensed electricity generation facility.
This structure may involve:
The storage unit is generally treated as part of the wider generation project and reflected in the preliminary license or generation license.
Turkey introduced a special investment framework allowing investors undertaking electricity storage commitments to apply for solar or wind generation projects under the licensing regime.
These projects are commonly known as:
The legal structure combines renewable generation with an electricity storage facility. It does not mean that the storage system itself automatically operates without licensing, permits, grid studies, or technical acceptance.
A standalone facility is not integrated into a particular generation plant. It may charge from the electricity system and later discharge electricity under the permitted market structure.
EMRA’s storage framework provides that standalone storage applications are handled through the supply-license route, while storage integrated into a generation facility is handled through the relevant preliminary-license or generation-license framework.
An existing generation-license holder may apply to add a storage unit to its facility.
This normally requires a license amendment and may also require:
The investor should not begin construction merely because the underlying power plant already holds a generation license.
Storage may also be used in certain unlicensed electricity generation projects, particularly self-consumption installations.
However, the legal analysis differs from licensed storage projects. The investor must review:
A project intended primarily for electricity trading should not be artificially structured as an unlicensed self-consumption facility.
The Energy Market Regulatory Authority, known internationally as EMRA and in Turkey as EPDK, is the principal regulatory authority for electricity-market licensing.
Depending on the project, other important authorities include:
Obtaining an EMRA preliminary license does not eliminate the need to obtain approvals from these other institutions.
Foreign investors may participate in Turkish energy storage projects through a company established under Turkish law.
The licensing applicant is generally expected to be a Turkish legal entity in the form permitted by electricity-market legislation. The applicant’s articles of association, shareholding structure, capital, management authority, and corporate purpose must comply with the regulatory requirements.
A foreign shareholder should therefore usually invest through:
The foreign parent company’s technical and financial experience may support the project, but the local applicant remains responsible for compliance with Turkish licensing rules.
Before filing an application, the project company should review:
Energy-project companies frequently require specific provisions in their articles of association concerning:
An application may be delayed where corporate documents do not match the proposed activity.
The required application depends on the type and stage of the project.
A new generation project generally requires a preliminary license before a production license can be obtained.
During the preliminary-license period, the project company must complete development obligations such as:
EMRA confirms that production activity generally requires an initial preliminary license, followed by a generation license after the preliminary-license obligations have been completed.
The generation license authorises the legal entity to carry out electricity generation activity in accordance with the approved project.
For a storage-integrated renewable project, the generation facility and storage unit must be accurately reflected in the licensing documentation.
A standalone electricity storage facility may require a supply-license application or an amendment to an existing supply license, depending on the applicant’s status and proposed activity.
EMRA announced that applications for standalone storage facilities would be accepted as supply-license applications, while integrated storage applications would be processed through preliminary-license or generation-license applications and amendments.
Turkish legislation provides a regulatory route for renewable generation projects associated with storage investment.
This framework has enabled applications for storage-integrated solar and wind projects. However, investors should not interpret this route as an unconditional entitlement to a generation license.
The application remains subject to:
The relationship between generation capacity, storage capacity, connection capacity, and technical design must be legally and technically consistent.
Energy storage projects use different technical units.
Megawatts measure instantaneous power capacity. In a battery system, this generally represents how quickly the system can charge or discharge electricity.
Megawatt-hours measure stored energy. This generally indicates how much electricity the battery can hold and deliver over time.
For example, a 50 MW/100 MWh battery may theoretically discharge at 50 MW for approximately two hours, subject to efficiency, operating limits, degradation, and technical constraints.
The licensing application should clearly distinguish between:
Inconsistent capacity descriptions can create material licensing and connection problems.
An energy storage project cannot be evaluated solely by reference to land and battery availability. The most important issue is often whether the electricity system can accommodate the project.
TEİAŞ or the relevant distribution company may assess:
Storage projects may impose both generation-type and consumption-type effects on the grid because they charge and discharge electricity at different times.
TEİAŞ published technical criteria addressing the connection of electricity storage facilities and their use in ancillary services, and later issued updated storage-related technical procedures and criteria.
Depending on the project type, the investor may require:
The connection documentation should specify:
A positive licensing decision should not be confused with final permission to energise the facility.
The documents vary according to whether the application concerns a new preliminary license, a generation-license amendment, a supply license, or an existing licensed facility.
A typical application file may include:
EMRA requires applications to follow the licensing regulation, official application procedures, and the applicable lists of information and documents.
Energy storage projects require substantial capital due to:
The applicant may need to demonstrate sufficient financial capacity and comply with minimum-capital requirements during the preliminary-license and licensing process.
The financial review should consider:
A project should not be financed solely on optimistic electricity-arbitrage assumptions.
EMRA applications may require:
The amount and form may change through annual EMRA decisions. Therefore, investors should verify the applicable 2026 fee and guarantee schedule immediately before filing.
An incorrect guarantee, expired bank letter, conditional wording, or insufficient amount can render an application incomplete.
The project company should secure appropriate rights over:
Possible land structures include:
A short-term or revocable lease may not provide adequate security for a long-term licensed project.
Energy storage facilities may require environmental review depending on:
The investor may require:
Environmental approval for the solar or wind plant should not automatically be assumed to cover a subsequently added battery facility.
A storage project may require:
Containerised battery systems are not necessarily exempt from construction or zoning requirements merely because they are modular or movable.
Battery fire risk is one of the most important legal and technical concerns.
The project design should address:
The investor should obtain documented confirmation that the system complies with applicable Turkish standards and the recognised international standards incorporated into the project contracts.
The battery supply agreement should regulate:
A simple equipment-sale agreement will rarely provide sufficient protection for a utility-scale storage project.
The Engineering, Procurement and Construction contract should clearly allocate responsibility for:
The investor should require measurable completion and performance tests rather than relying on general statements that the plant will be delivered on a turnkey basis.
Before commercial operation, the facility may need to complete:
The acceptance criteria should be coordinated across:
Conflicting acceptance definitions may produce disputes over whether the project has legally and commercially reached completion.
The commercial rights of a storage facility depend on its regulatory structure.
Potential revenue models may include:
However, not every theoretical revenue stream is automatically available to every storage facility.
The investor must confirm:
Turkey’s developing aggregation framework may create additional opportunities for distributed energy resources and storage assets.
A storage investor should nevertheless distinguish between:
Each activity may be subject to separate regulatory conditions.
Storage facilities require accurate measurement of:
The metering configuration should prevent double counting and should be consistent with market-settlement rules.
Incorrect metering may result in:
A battery’s capacity normally decreases over time.
The project agreements should define:
A 100 MWh battery may not provide 100 MWh of usable energy throughout its operating life.
The financial model and license documentation should avoid confusing nominal capacity with guaranteed usable capacity.
The sale of shares in a licensed or preliminary-license project company may require regulatory analysis.
The parties should review:
The transaction may require:
A transaction should not close before determining whether the regulatory approval is a condition precedent.
A preliminary license or license cannot be treated as an ordinary freely transferable asset.
An asset-sale structure may affect:
In many cases, investors prefer a share acquisition of the licensed project company because the company remains the holder of the regulatory rights. Even then, a change-of-control review is necessary.
The preliminary-license holder must complete the obligations specified in the licensing regulation and EMRA decision within the permitted period.
These may include:
Failure to meet a critical deadline may result in:
Extensions may be possible only under the applicable regulatory provisions and facts of the case.
Potential grounds may include:
Commercial difficulty, financing failure, supplier delay, or poor project management may not automatically justify an extension.
The project company should submit any extension request before the relevant deadline and support it with detailed evidence.
An application may be rejected because of:
The investor should request a written decision identifying the legal and technical grounds for rejection.
An adverse EMRA decision may potentially be challenged through administrative-law remedies.
Depending on the decision, the applicant may consider:
The filing period for an administrative lawsuit is strict. The investor should calculate the deadline from the lawful notification or publication of the relevant decision and should not assume that informal negotiations suspend the period.
A project may face disputes regarding:
The legal strategy may involve EMRA, TEİAŞ, the distribution company, technical experts, and administrative courts.
A technical expert report may be decisive in showing that the proposed project satisfies the applicable criteria.
Non-compliance may result in:
Serious risks include:
A foreign investor acquiring a storage project should review:
The investor should not rely solely on the existence of a preliminary-license document.
Energy storage is moving from the application and development phase into actual construction and operation. EMRA maintains 2026 licensing records, while TEİAŞ continues to apply storage-specific technical criteria and grid procedures.
By 2026, the principal legal priorities for investors include:
The fact that Turkey’s first projects have moved through licensing and toward operation demonstrates that the storage framework is no longer purely theoretical. At the same time, project-specific regulatory, financing, and construction risks remain substantial.
Not always. The required structure depends on whether the facility is integrated into a licensed generation plant, developed as a standalone storage project, or used within an eligible unlicensed generation facility.
EMRA is the principal licensing authority. TEİAŞ, distribution companies, environmental authorities, municipalities, and other public institutions also participate in project approval and connection procedures.
A foreign investor generally participates through an eligible company incorporated under Turkish law. The Turkish project company files the application and holds the regulatory rights.
A standalone facility is generally addressed through the supply-license framework rather than an ordinary generation license. The precise structure should be confirmed according to the planned market activity.
Yes, subject to the applicable license-amendment, grid-connection, project-approval, environmental, technical-acceptance, and permit requirements.
No. A preliminary license enables the holder to complete project-development obligations. Construction should begin only after the necessary land, environmental, zoning, technical, connection, and construction approvals have been obtained.
MW indicates the battery’s charging or discharging power. MWh indicates the amount of energy it can store. Both values must be accurately stated in the application and project contracts.
It is not an ordinary freely transferable asset. A project acquisition usually requires a structured share or asset transaction and may require EMRA approval, notification, or license amendment.
The preliminary license may be cancelled, the production-license application may fail, guarantees may be affected, and the project may lose its connection rights.
Yes. Depending on the circumstances, the investor may request reconsideration, correct deficiencies, submit objections, or file an administrative lawsuit seeking annulment and, where appropriate, a stay of execution.
Energy storage projects require coordinated legal advice covering electricity-market licensing, corporate law, foreign investment, land rights, environmental approvals, construction, grid connection, project finance, battery procurement, EPC contracts, insurance, and administrative litigation.
Fırat Fesih Kaya Law Office advises foreign investors, renewable energy developers, battery manufacturers, infrastructure funds, lenders, EPC contractors, supply companies, and project sponsors involved in electricity storage investments in Turkey.
Our legal services may include:
Early legal review can help prevent incomplete applications, loss of grid capacity, invalid project transfers, missed preliminary-license deadlines, defective supply contracts, and costly disputes with regulators, contractors, lenders, or project partners.
Phone: +90 312 434 22 22
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Email Address: info@firatfesihkaya.av.tr
Office Address: Mevlana Boulevard No:221, Yıldırım Tower No:148, 06520 Balgat, Çankaya, Ankara, Turkey
This article is provided for general informational purposes only and does not constitute legal advice. Energy storage projects must be assessed according to their technology, connection point, licensing structure, market activity, land status, and project-specific regulatory circumstances.