A 2026 guide to electricity market settlement disputes in Turkey covering EPİAŞ settlements, meter errors, imbalance costs, Day-Ahead and Balancing Power Market calculations, objections, evidence, compensation and legal remedies for producers and suppliers.

Electricity market settlement disputes can create substantial financial exposure for electricity producers, suppliers, renewable energy companies and foreign investors operating in Turkey.

A power plant may generate the correct amount of electricity and comply with its generation schedule but nevertheless receive a settlement statement that the company believes incorrectly calculates its receivable. A supplier may unexpectedly face significant imbalance costs. Metering data may be incorrect, generation may be attributed to the wrong settlement period, or a market participant may dispute the calculation methodology applied to its transactions.

For large market participants, relatively small calculation differences can produce significant financial consequences when multiplied across thousands of MWh.

Turkey’s electricity settlement framework is primarily governed by the Electricity Market Balancing and Settlement Regulation, while electricity market settlement operations are carried out within the organized market structure operated by EPİAŞ. EPDK continues to list the Balancing and Settlement Regulation and its associated procedures among the principal electricity-market regulations in force. (EPDK)

For producers and suppliers, the central question is therefore not merely whether a settlement figure appears incorrect. The company must determine:

What caused the calculation → Which market data produced the result → Who is responsible → What objection procedure applies → What evidence proves the error → What financial correction should be requested?

What Is Electricity Market Settlement in Turkey?

Settlement is the financial calculation process through which electricity-market transactions are converted into amounts payable or receivable by market participants.

Electricity markets involve considerably more than simply measuring how much electricity a producer generated.

A participant’s financial position can depend on several components, including scheduled electricity, actual generation or consumption, Day-Ahead Market transactions, Intraday Market transactions, balancing activities, imbalances, meter readings and other regulatory settlement components.

Accordingly:

Physical Electricity Flow ≠ Final Financial Settlement.

A company can physically produce electricity successfully while still encountering a significant financial settlement dispute.

Who Can Face a Settlement Dispute?

Settlement disputes can affect numerous electricity-market participants.

The most common include licensed generation companies, electricity suppliers, renewable-energy producers, aggregators, portfolio managers and companies participating directly or indirectly in organized electricity markets.

Foreign investors acquiring Turkish electricity businesses should therefore treat settlement history as a financial and regulatory due diligence issue.

What Causes Electricity Settlement Disputes?

Settlement disputes can arise from many different sources.

Common examples include:

Incorrect Meter Data

Missing Meter Data

Incorrect Generation Data

Wrong Settlement Period

Imbalance Calculations

Day-Ahead Market Transactions

Intraday Market Transactions

Balancing Power Market Instructions

YEKDEM-Related Calculations

Loss Coefficients

Incorrect Participant or Portfolio Attribution

System or Software Errors

Retroactive Corrections

Incorrect Market Parameters

Determining which component produced the disputed amount is usually the first major step.

Meter Data Disputes

Metering data forms the foundation of many settlement calculations.

Suppose a solar plant actually exports 12,000 MWh during a settlement period but the relevant settlement system records only 10,500 MWh.

The difference can directly affect the project’s receivable.

The investor should immediately preserve:

Primary Meter Records → Backup Meter Records → SCADA Data → TEİAŞ or Distribution Data → Settlement Records → Plant Generation Reports.

A settlement objection becomes considerably stronger when several independent technical data sources demonstrate the same discrepancy.

Missing Meter Data

Sometimes the issue is not incorrect data but missing data.

Communication failures, meter failures or data-transfer problems can potentially result in estimated, incomplete or subsequently corrected information.

The market participant should establish exactly how substitute data was calculated and whether the applicable methodology was correctly applied.

Waiting several months can make technical reconstruction significantly harder.

SCADA Data Versus Settlement Meter Data

A frequent misunderstanding is assuming that SCADA generation data necessarily determines settlement.

SCADA data is extremely valuable evidence, but settlement normally depends on the metering and market data recognized under the applicable regulatory framework.

Accordingly, where SCADA and settlement data differ, the company should investigate the reason rather than simply asserting that the SCADA figure must automatically prevail.

The discrepancy itself can nevertheless be important evidence of a metering or data-processing problem.

Imbalance Settlement Disputes

Imbalance costs are one of the most commercially important sources of electricity-market disputes.

A participant’s actual physical position may differ from its scheduled or contracted position.

That difference can create an energy imbalance.

Depending on market conditions and the applicable settlement methodology, substantial imbalance charges can arise.

For renewable producers, forecasting error can make this particularly important.

Wind and solar generation cannot always be predicted with complete accuracy.

Unexpectedly High Imbalance Costs

Suppose a wind producer normally incurs manageable imbalance costs but suddenly receives a settlement showing several times its historical monthly exposure.

The company should not automatically assume the market calculation is wrong.

It should first examine:

Generation Forecast → Actual Generation → Market Position → Relevant Prices → Settlement Parameters → Meter Data → Portfolio Position.

The problem may arise from the company’s own forecast, a portfolio error, incorrect meter information or application of a settlement parameter.

Each scenario has different legal consequences.

2026 Imbalance Calculation Changes

Settlement disputes require particular attention to the version of the rules applicable to the relevant period.

Before 2026, EPDK opened for consultation decisions concerning the coefficients used in calculating energy imbalance amounts from 1 January 2026. (EPDK)

In June 2026, EPDK also opened further proposed amendments to the Electricity Market Balancing and Settlement Regulation and related settlement parameters for public consultation. (EPDK)

This makes one point especially important for disputes:

The applicable settlement rules must be identified according to the exact settlement period.

A calculation should not be challenged using a methodology that entered into force only after the disputed month.

Day-Ahead Market Settlement Disputes

Day-Ahead Market transactions can also generate disputes.

Participants submit offers and establish market positions before physical delivery.

Errors concerning accepted offers, quantities, market prices or participant positions can therefore affect financial settlement.

A company challenging a Day-Ahead Market calculation should preserve the original offer data and system confirmations.

The evidence should establish exactly what was submitted, accepted and ultimately included in settlement.

Intraday Market Disputes

Intraday transactions can further modify a participant’s position.

This creates another layer of data that must be reconciled when a settlement discrepancy occurs.

The company should reconstruct the transaction timeline rather than reviewing only the final invoice.

For complicated disputes, the legal and financial team may need to create:

Day-Ahead Position → Intraday Transactions → Physical Generation → Balancing Instructions → Final Imbalance → Settlement Amount.

This provides a clear explanation of where the disputed amount entered the calculation.

Balancing Power Market Disputes

The Balancing Power Market can create particularly complex disputes because system-operation instructions and actual compliance can affect settlement.

Questions may arise concerning whether an instruction was received, whether it was properly implemented, what quantity was delivered and how performance was recorded.

Interestingly, EPDK’s June 2026 regulatory consultation included a draft decision concerning the reporting of instructions that were not fulfilled in the Balancing Power Market. (EPDK)

For producers participating in balancing activities, preserving dispatch and operational records is therefore increasingly important.

What Evidence Should Producers Preserve?

A producer facing a settlement dispute should immediately preserve its complete technical and market record.

This normally includes:

Settlement Notifications

Meter Records

SCADA Data

Generation Reports

Market Offers

Accepted Transactions

Balancing Instructions

EPİAŞ System Records

TEİAŞ Communications

Invoices

Market Prices

Portfolio Records

Internal Emails

Technical Incident Reports

Evidence should be collected before systems overwrite historical operational data.

EPİAŞ Settlement Notifications

Market participants should carefully review settlement notifications rather than treating them as routine accounting documents.

EPİAŞ continues to issue preliminary and settlement-related notifications to electricity-market participants. Its public settlement notices show that participants are expected to check settlement information and raise objections where necessary. (EPİAŞ)

This makes internal settlement review an important compliance function.

Large producers and suppliers should ideally reconcile settlement information every month.

Why Objection Deadlines Matter

Electricity-market disputes are highly procedural.

A company may possess excellent evidence demonstrating that a calculation is incorrect but still damage its position by failing to object within the applicable procedure.

The responsible team should therefore identify immediately:

Notification Date → Objection Deadline → Required Platform → Required Documentation → Responsible Employee → Submission Confirmation.

The objection should be filed before the deadline rather than waiting for a complete commercial dispute to develop.

What Should a Settlement Objection Contain?

A strong objection should be specific.

It should identify the settlement period, disputed calculation, relevant quantity, applicable market rule and requested correction.

For example, stating:

“April settlement is incorrect”

provides very little assistance.

A more effective objection identifies:

Relevant Hour → Recorded Generation → Correct Generation → Difference → Settlement Effect → Supporting Meter Evidence.

The objective is to make the alleged error independently reproducible.

Preliminary Settlement Versus Final Settlement

Market participants should also distinguish between preliminary settlement information and later settlement stages.

An error discovered during preliminary review may be significantly easier to correct before final invoicing consequences arise.

This is why electricity companies should not wait until accounting personnel notice an unusual invoice weeks later.

Technical, trading and accounting teams should review settlement information together.

Can a Final Settlement Still Be Challenged?

The answer depends on the applicable procedure, nature of the error and stage reached by the settlement.

Finalization does not necessarily mean every possible legal remedy disappears.

However, failing to use an available earlier objection mechanism can create procedural and evidentiary difficulties.

The company should therefore seek legal review immediately when a material discrepancy is discovered.

Retroactive Settlement Corrections

Another important problem arises when historical settlement periods are recalculated.

A producer or supplier may believe that a month is financially closed and later receive an adjustment affecting earlier periods.

The company should determine:

Why Was the Period Reopened?

Which Data Changed?

What Legal Rule Permits the Correction?

Was the Correct Methodology Applied?

Were All Affected Participants Treated Consistently?

Retroactive corrections can become particularly material when several months are recalculated simultaneously.

Supplier Settlement Disputes

Suppliers face different risks from generation companies.

Their settlement exposure can depend on customer consumption, portfolio movements, forecasting, bilateral contracts and market transactions.

A supplier may therefore face unexpected liabilities because consumption was allocated incorrectly or because customer movements were recorded in the wrong period.

Large suppliers should maintain detailed reconciliation between customer portfolio data and market settlement information.

Portfolio Attribution Errors

Incorrect attribution can create substantial problems.

Suppose electricity consumption or generation belonging to one participant is incorrectly included in another participant’s portfolio.

The affected company may face imbalance costs or settlement liabilities for electricity that economically belongs elsewhere.

The dispute should therefore identify both:

Physical Point and Responsible Market Participant.

Correcting only the financial total without correcting the underlying attribution can allow the problem to repeat.

Aggregator-Related Settlement Issues

The growing role of aggregation can create additional settlement complexity.

Where multiple generation or consumption facilities are managed within an aggregated portfolio, data quality and portfolio attribution become even more important.

A settlement error affecting one facility can influence the financial position of the wider portfolio.

Contracts between aggregators and portfolio participants should therefore clearly allocate settlement-error risk and correction mechanisms.

YEKDEM Settlement Disputes

Renewable-energy producers can also face disputes involving YEKDEM-related financial calculations.

The project should distinguish between disputes concerning:

Eligible Generation

Meter Data

Applicable Support Price

Settlement Calculation

Grid-Sourced Electricity

Storage-Related Electricity

For storage-integrated projects, separating electricity genuinely generated from renewable resources from other energy flows can be particularly important.

Hybrid Power Plants

Hybrid projects can also create settlement complications.

A multi-source facility may contain wind and solar generation behind a common electrical connection.

The investor should ensure that metering and settlement arrangements correctly reflect the project’s licensed structure.

This becomes especially important where different components of the project have different commercial or regulatory characteristics.

Battery Storage Settlement Disputes

Battery energy storage introduces another layer of complexity.

The market participant must distinguish between:

Electricity Generated → Electricity Stored → Electricity Drawn From Grid → Electricity Discharged → Storage Losses.

Incorrect treatment of any of these energy flows can affect settlement.

Foreign investors acquiring storage projects should therefore examine historical settlement methodology as part of due diligence.

Incorrect Market Price

A settlement dispute can also involve application of an incorrect price.

The company should determine which price should legally apply to the specific transaction and settlement interval.

This can involve Day-Ahead prices, balancing prices, bilateral contractual prices or another applicable market value.

The calculation should be independently reconstructed.

System Error or Software Error

Electricity settlement depends heavily on digital systems.

Software errors, communication failures or incorrect data uploads can therefore create financial discrepancies.

When a suspected system error occurs, the company should preserve screenshots, timestamps, error messages and correspondence.

These records can later establish that the participant attempted to submit correct information but was prevented by a technical problem.

Cybersecurity and Settlement Data

Market participants should also consider cybersecurity.

Unauthorized changes to bidding information, account access or operational data could potentially produce substantial market losses.

The company should maintain access logs and investigate unusual activity immediately.

Cyber incidents should be treated as both technical-security events and potential financial disputes.

Can EPDK Become Involved?

Depending on the nature of the dispute, regulatory issues can potentially be brought before EPDK through the applicable mechanisms.

EPDK’s own guidance confirms more generally that where a dispute with a supplier, distribution company or TEİAŞ concerns conduct alleged to violate electricity-market legislation, an application supported by the relevant documents can be made to the regulator following the applicable complaint process. (EPDK)

However, not every commercial settlement disagreement automatically becomes an EPDK proceeding.

The correct route depends on the nature of the disputed conduct.

Administrative Litigation

Where the dispute ultimately concerns an administrative decision made by EPDK or another public authority, judicial review before the competent administrative court may become relevant.

Potential arguments can concern:

Authority → Procedure → Interpretation of Regulation → Calculation Methodology → Factual Error → Equal Treatment.

Applicable filing periods must be identified immediately.

Commercial Litigation

Other electricity disputes may be contractual or commercial in nature.

For example, a settlement error between private contractual counterparties may create a payment or indemnification dispute.

In that case, the applicable contract, jurisdiction clause, arbitration clause and mandatory procedural requirements must be examined.

The forum should therefore never be selected merely because the dispute concerns electricity.

Arbitration

Energy contracts frequently contain arbitration provisions.

A dispute between a producer and supplier under a bilateral PPA may therefore proceed differently from a regulatory settlement challenge involving EPİAŞ or EPDK.

Foreign investors should review dispute-resolution clauses before commencing proceedings.

An incorrectly chosen forum can waste substantial time.

Can Compensation Be Claimed?

Potentially.

If an incorrect settlement causes financial loss and a legally responsible party can be identified, the participant may investigate recovery of that loss.

Potential claims can include:

Underpaid Electricity Revenue

Incorrect Imbalance Charges

Incorrect Market Charges

Financing Costs

Interest

Other Directly Proven Losses

The recoverability of each category depends on the legal basis of the claim.

Interest on Underpaid Amounts

Interest can become significant in large settlement disputes.

If a producer was underpaid for electricity generated several years earlier, the principal amount may represent only part of the claim.

The applicable interest regime depends on the legal relationship and nature of the receivable.

It should therefore be calculated separately rather than automatically applying a generic commercial rate.

Expert Evidence

Complex settlement litigation frequently requires technical or financial expertise.

A settlement expert may need to reconstruct:

Meter Data → Market Position → Applicable Formula → Market Price → Settlement Result.

The best expert reports make the disputed calculation reproducible.

A court or regulator should be able to understand precisely how the claimant reached the requested correction.

Example: Solar Producer Underpaid Because of Meter Error

A 100 MW solar project produces electricity throughout July.

The settlement statement records materially less electricity than the project’s technical records.

The company should compare primary meter data, backup meter information, SCADA records and settlement quantities.

If the discrepancy results from incorrect market data, the company should submit the applicable objection promptly and preserve the evidence necessary to quantify the underpayment.

Example: Wind Producer Faces Unexpected Imbalance Charge

A wind farm receives an unusually large imbalance liability.

The project initially assumes that EPİAŞ made a calculation error.

Further investigation reveals that incorrect generation forecasts were uploaded for several settlement periods.

The legal strategy will be completely different depending on whether the error originated with the market operator, the producer or a third-party forecasting service.

Identifying causation therefore comes before litigation.

Example: Supplier Receives Retroactive Adjustment

A supplier receives a major adjustment relating to several historical months.

The company should request and reconstruct the underlying data and identify exactly why the historical settlement changed.

If the adjustment resulted from corrected meter data, the supplier should verify whether the correction itself and the subsequent calculation comply with the applicable rules.

Example: Foreign Investor Acquires a Supplier

A foreign energy company acquires a Turkish electricity supplier.

After closing, historical settlement corrections create several million euros of unexpected liabilities.

The buyer discovers that the SPA contained only generic regulatory warranties.

This demonstrates why settlement exposure should be separately investigated in energy-sector M&A.

Settlement Due Diligence Before Acquiring a Producer

A buyer acquiring a generation company should examine at least the previous settlement history, material objections, unresolved corrections, imbalance exposure and any regulatory disputes.

The financial team should reconcile:

Generation → Metering → Settlement → Invoice → Cash Received.

Material unexplained differences require investigation.

Settlement Due Diligence Before Acquiring a Supplier

Supplier acquisitions require even broader analysis.

The buyer should examine:

Customer Portfolio → Consumption Data → Market Positions → Imbalances → Settlement Statements → Historical Corrections → Outstanding Objections → Unpaid Amounts.

Settlement liabilities can represent hidden working-capital exposure.

SPA Protection

Where material historical uncertainty exists, the buyer can seek specific contractual protection.

Possible structures include:

Specific Warranty

Specific Indemnity

Escrow

Purchase Price Retention

Pre-Closing Settlement Correction

Post-Closing Cooperation Covenant

The appropriate mechanism depends on the size and probability of the exposure.

2026 Regulatory Risk

Settlement models should not be assumed to remain static.

EPDK opened proposed amendments to the Balancing and Settlement Regulation and several related market mechanisms for consultation in June 2026, including changes concerning settlement coefficients and reporting of unfulfilled Balancing Power Market instructions. (EPDK)

For producers, suppliers and foreign investors, this reinforces the importance of monitoring regulatory changes and updating settlement systems accordingly.

A calculation methodology that was correct in 2025 may not necessarily remain correct for every 2026 settlement period.

Major Settlement Dispute Red Flags

Investors should investigate carefully where there are repeated settlement objections, unexplained meter differences, unusually high imbalance costs, major retroactive corrections, recurring SCADA-to-meter discrepancies, unresolved EPİAŞ correspondence, balancing instruction disputes, historical YEKDEM corrections, manual data adjustments, unexplained portfolio transfers or significant settlement receivables outstanding for long periods.

These issues can indicate both financial and compliance risk.

Electricity Settlement Dispute Strategy

When a material discrepancy is identified, the company should proceed systematically:

Identify Settlement Period → Preserve Deadline → Download Original Data → Compare Meter and SCADA Records → Reconstruct Market Position → Identify Applicable 2026 Rules → Calculate Correct Settlement → Determine Responsible Party → Submit Objection → Preserve Evidence → Evaluate Regulatory, Judicial or Contractual Remedies.

The biggest mistake is waiting until the annual audit to investigate a settlement problem that should have been challenged months earlier.

Frequently Asked Questions

1. What is an electricity market settlement dispute?

It is a disagreement concerning the calculation or financial settlement of electricity-market transactions, including generation, consumption, imbalance, metering or organized market positions.

2. Who operates electricity market settlement in Turkey?

EPİAŞ performs central organized electricity-market and settlement functions within the regulatory framework established by electricity-market legislation.

3. Can a producer challenge incorrect settlement data?

Yes, subject to the applicable settlement and objection procedures. Market participants should review notifications promptly and preserve the applicable objection periods.

4. Can incorrect meter data affect payment to a power plant?

Yes. Meter data can directly influence the amount of electricity recognized for settlement.

5. Can imbalance charges be challenged?

Potentially. The company must identify whether the charge results from correct application of the applicable methodology or from incorrect data, attribution or calculation.

6. Can SCADA data prove a settlement error?

SCADA records can provide important technical evidence, although the legally relevant settlement data and metering framework must also be examined.

7. Can historical settlements be corrected?

Settlement corrections can occur under the applicable framework. A participant affected by a retroactive adjustment should verify both the underlying data correction and the resulting recalculation.

8. Can EPDK become involved in an electricity settlement dispute?

Depending on the nature of the alleged regulatory violation, an application to EPDK may be available. The precise procedural route depends on the dispute.

9. Can a foreign investor recover losses caused by an incorrect settlement?

Potentially, where the investor establishes an actionable legal basis, responsibility, causation and recoverable financial loss.

10. What should a foreign investor check before buying a Turkish electricity producer or supplier?

Historical settlement statements, meter reconciliations, imbalance exposure, outstanding objections, retroactive corrections and pending regulatory or contractual disputes should all be reviewed.

Legal Support for Electricity Market Settlement Disputes in Turkey

Electricity settlement disputes are rarely resolved by looking at a single invoice. A proper investigation normally requires reconstruction of the entire chain from physical electricity flow to meter data, market position, settlement formula and final payment.

Firat Fesih Kaya Law Office assists foreign investors, electricity producers, renewable-energy companies and suppliers with electricity-market disputes in Turkey. Firat Fesih Kaya can assist with settlement objections, imbalance disputes, metering disagreements, EPİAŞ-related disputes, EPDK proceedings, compensation claims, commercial disputes and due diligence for electricity-sector acquisitions.

For producers and suppliers, the most important practical rule is simple: review every material settlement promptly, preserve the objection deadline and reconstruct the disputed calculation before deciding which legal remedy to pursue.

Phone: +90 312 434 22 22
Mobile Phone: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No: 221, Yildirim Tower, Balgat, Cankaya / Ankara, Turkey