Solar Plus Storage Projects in Turkey: Legal Requirements for Foreign Investors – 2026 Updated Guide

Planning a solar plus battery storage investment in Turkey? Learn the 2026 rules on EMRA licensing, preliminary licenses, TEİAŞ grid connection, battery storage, land rights, permits, project finance, M&A, and legal due diligence for foreign investors.

Turkey’s rapidly developing renewable-energy market has created significant opportunities for foreign investors seeking to combine solar photovoltaic generation with battery energy storage systems (BESS).

Solar-plus-storage projects can provide commercial advantages over conventional solar facilities by enabling electricity to be stored, improving operational flexibility, supporting grid management, and potentially allowing participation in additional electricity-market services.

However, the legal structure of a solar-plus-storage investment in Turkey is substantially more complex than simply installing batteries next to an existing solar power plant.

Foreign investors must consider EMRA licensing, preliminary-license requirements, storage capacity, TEİAŞ grid connection, land rights, environmental and construction approvals, battery safety, EPC contracts, project financing, electricity-market rules, and change-of-control restrictions.

The regulatory environment is also developing rapidly. In February 2026, TEİAŞ replaced its previous electricity-storage grid connection criteria with a revised final framework. In July 2026, it also replaced the earlier technical criteria governing the use of storage facilities in ancillary services.

For international investors, this means that a solar-plus-storage project assessed under older technical assumptions should be re-examined before acquisition, financing, or construction.

How Are Solar Plus Storage Projects Regulated in Turkey?

Turkey does not regulate a solar-plus-storage project as merely a conventional solar facility with additional equipment.

Electricity storage is part of the regulated electricity-market framework.

The principal legal framework includes Electricity Market Law No. 6446, the Electricity Market Licensing Regulation, the Regulation on Electricity Storage Activities in the Electricity Market, the Electricity Grid Regulation, connection and system-use rules, EMRA decisions, and TEİAŞ technical requirements.

EMRA’s regulatory framework expressly recognizes electricity storage units integrated into electricity-generation facilities and standalone electricity-storage facilities.

Accordingly, the precise regulatory structure of the investment should be determined before the foreign investor commits capital.

1. Determine the Exact Project Structure

The first legal question should be:

What exactly is the investor acquiring or developing?

A transaction may involve a development-stage solar-plus-storage project, a preliminary-license company, an operating solar facility to which storage will be added, a project company awaiting construction, or a portfolio containing several storage-integrated projects.

These structures do not necessarily present identical regulatory issues.

The investor should therefore identify the legal status of both the solar generation component and the storage component.

2. Preliminary License Requirements

For licensed electricity generation, Turkey generally operates a two-stage authorization system.

A legal entity first obtains a preliminary license and, after completing the applicable development obligations, proceeds to the generation-license stage.

EMRA explains that the preliminary license allows the project company to obtain the permits, approvals, licenses, and similar rights required to begin the generation investment.

Foreign investors buying a development-stage solar-plus-storage project should therefore never treat a preliminary license as equivalent to a completed generation license.

The due diligence should establish precisely which preliminary-license obligations remain outstanding.

3. Moving from Preliminary License to Generation License

The transition to a generation license is one of the most important stages of the project.

The investor should examine whether the project company has completed all applicable requirements relating to land, environmental approvals, zoning, construction, technical matters, grid connection, corporate structure, and other preliminary-license obligations.

Failure to complete material obligations within the applicable period can threaten project development.

This issue has particular significance in 2026 because EMRA reported that storage-integrated projects have been progressing from preliminary licenses to generation licenses. In a 2026 sector statement, EMRA reported that 23 storage-integrated projects totaling 1,070 MW had received generation licenses after completing preliminary-license obligations.

This demonstrates that the Turkish storage-integrated generation market is moving from development-stage licensing toward actual implementation.

4. Grid Connection Is a Fundamental Investment Right

For solar-plus-storage projects, grid connection is not merely an engineering issue.

It can determine the commercial value of the project.

Foreign investors should verify:

• approved connection point;
• connection capacity;
• generation capacity;
• storage power and energy capacity;
• connection agreement status;
• system-use arrangements;
• network reinforcement requirements;
• transmission or distribution connection;
• technical restrictions;
• outstanding connection obligations.

A seller’s statement that a project has “secured grid capacity” should never replace documentary verification.

5. Major 2026 TEİAŞ Storage Connection Rules

One of the most important developments affecting storage investors occurred on February 27, 2026.

On that date, TEİAŞ published its revised final Grid Connection and Compliance Criteria for Electricity Storage Facilities.

Importantly, TEİAŞ expressly withdrew the earlier criteria published on December 30, 2024.

This matters directly to solar-plus-storage investors.

A technical study prepared in 2024 or 2025 may have relied on criteria that are no longer current.

Therefore, foreign investors conducting due diligence in 2026 should require the project’s technical advisers to confirm compliance with the February 2026 criteria.

6. Connection Capacity Must Match the Investment Model

A common investment mistake is assuming that the size of the solar plant and the size of the storage facility can be determined purely by commercial preference.

The actual configuration must comply with the applicable licensing and grid framework.

The investor should compare:

generation capacity, storage power, storage energy capacity, connection capacity, and the licensed project configuration.

Any discrepancy should be investigated.

This becomes particularly important where a seller markets a project using headline MW or MWh figures that do not correspond precisely to its regulatory rights.

7. Transmission Infrastructure Can Create Additional Costs

Some solar-plus-storage projects may require new transmission infrastructure.

This can substantially affect project economics.

A significant 2026 development occurred on February 18, when TEİAŞ introduced rules governing transmission investments constructed jointly by legal entities on behalf of TEİAŞ where new facilities are necessary to connect generation projects to the transmission system.

Foreign investors should therefore determine whether their project depends on future transmission infrastructure and, if so, who bears the construction, financing, timing, and completion risk.

8. Land Rights Must Cover Both Solar and Storage Infrastructure

A solar-plus-storage facility requires more than land for photovoltaic panels.

The project may also require land for:

• battery containers;
• inverters;
• transformers;
• control buildings;
• substations;
• fire-safety infrastructure;
• access roads;
• transmission lines;
• auxiliary equipment.

The investor should ensure that every component is located within land legally controlled by the project company.

Title deeds, leases, easements, mortgages, attachments, zoning restrictions, and access rights should all be reviewed.

9. Foreign Investor Land Restrictions Must Be Considered

Foreign investors frequently develop Turkish renewable projects through locally incorporated project companies.

However, the nationality and ownership structure of the project company can become relevant to certain real-estate acquisitions and strategic-area restrictions.

Foreign investors should therefore examine the land structure before acquisition rather than assuming that purchasing the project company’s shares automatically eliminates all land-law considerations.

Where the project uses leased or public land, the effect of change of control should also be investigated.

10. Environmental and Construction Permits

Solar energy is renewable, but solar-plus-storage projects remain subject to environmental, construction, zoning, safety, and other project-specific requirements.

For preliminary-license projects, timing is particularly important.

EMRA’s licensing guidance provides, among other development-stage requirements, that preliminary-license holders must apply for the necessary decision under the environmental impact assessment framework within the applicable preliminary-license timetable.

Foreign investors should therefore examine not only whether an approval exists, but whether it covers the current project configuration.

Adding or materially modifying storage can require renewed legal analysis.

11. Battery Fire and Safety Requirements

Battery storage creates risks that conventional solar projects do not present to the same extent.

Depending on technology and configuration, these can include:

• thermal runaway;
• fire;
• explosion;
• hazardous emissions;
• electrical failure;
• neighboring property damage.

Legal due diligence should therefore be coordinated with specialist battery and fire-safety engineering review.

The EPC and battery-supply contracts should clearly allocate responsibility for safety design, testing, emergency systems, defects, and manufacturer failures.

12. Review the Battery Supply Agreement

The battery supply agreement can contain some of the most valuable contractual protections in the entire project.

Foreign investors should examine:

• battery chemistry;
• rated power;
• usable capacity;
• degradation;
• cycle life;
• round-trip efficiency;
• availability;
• warranty period;
• replacement obligations;
• testing procedures;
• manufacturer guarantees.

A battery warranty lasting substantially less than the project’s financing period can create a significant long-term risk.

13. Degradation Is a Legal and Financial Risk

Battery capacity decreases over time.

Therefore, the investor should not focus only on the battery’s initial MWh rating.

The supply agreement should establish measurable degradation guarantees and remedies if performance falls below the guaranteed curve.

For an acquisition, actual historical degradation should be compared with contractual warranties.

If performance has already deteriorated faster than expected, the buyer should determine whether warranty claims remain available.

14. EPC Contract Risks

Solar-plus-storage EPC contracts require careful coordination between solar generation equipment, storage systems, electrical infrastructure, and grid compliance.

The EPC contract should address:

• completion;
• delay;
• performance testing;
• grid compliance;
• battery integration;
• liquidated damages;
• warranties;
• defects;
• commissioning;
• acceptance.

Interface risk is particularly important where different contractors supply the solar facility and BESS.

The contract structure should make clear who bears responsibility if the combined facility fails its commissioning tests.

15. O&M Agreements

The investor should also examine long-term operation and maintenance arrangements.

Solar maintenance and battery maintenance may be performed by different contractors.

This creates interface risk.

The agreements should establish responsibility for monitoring, battery management, software updates, preventive maintenance, emergency response, spare parts, performance reporting, and cybersecurity.

16. Software and Data Rights

Battery projects depend heavily on software.

The investor should verify rights relating to:

• Battery Management Systems;
• Energy Management Systems;
• SCADA;
• remote monitoring;
• optimization software;
• operational data;
• cybersecurity.

A foreign buyer should ensure that all critical software licenses remain effective following a change of ownership.

Owning the physical batteries without enforceable access to essential operating software can create serious operational problems.

17. Ancillary Services and the July 2026 Update

Storage facilities may potentially generate revenue from services beyond conventional electricity generation and sale.

However, eligibility should never be assumed.

On July 3, 2026, TEİAŞ published an updated version of its technical criteria and testing procedures governing electricity storage units and facilities used in ancillary services. The December 2024 version was withdrawn.

Accordingly, ancillary-service revenue assumptions in a 2026 investment model should be tested against the current technical criteria.

A projected revenue stream is not the same as an established regulatory entitlement.

18. Project Finance Risks

Solar-plus-storage projects can require substantial capital expenditure.

Lenders will therefore examine:

• EMRA licensing;
• grid connection;
• preliminary-license milestones;
• construction risk;
• battery technology;
• degradation guarantees;
• manufacturer creditworthiness;
• insurance;
• project revenues;
• land rights.

Financing agreements may also contain change-of-control restrictions.

Foreign investors acquiring an existing project should obtain lender consent where required before closing.

19. Security Package

Project lenders may hold security over:

• project-company shares;
• bank accounts;
• receivables;
• equipment;
• land;
• insurance proceeds;
• project contracts.

The buyer should map the entire security structure.

If financing will be repaid at closing, the transaction documentation should contain simultaneous release mechanisms.

20. Buying an Existing Solar Plus Storage Project

Foreign investors increasingly encounter projects being marketed before construction is complete.

The buyer should conduct full legal, regulatory, technical, financial, environmental, and tax due diligence.

Particular attention should be given to whether the project has genuinely secured the rights represented by the seller.

The buyer should independently verify EMRA authorization, grid rights, land, permits, technical configuration, and preliminary-license milestones.

21. Change of Control

The acquisition itself may trigger energy-regulatory requirements.

The buyer should determine whether direct or indirect ownership changes require EMRA approval, notification, license amendment, or another regulatory procedure.

This analysis should be completed before signing, not after closing.

The SPA should make any mandatory regulatory procedure a condition precedent where appropriate.

22. Competition Clearance

Large renewable-energy acquisitions may also require analysis under Turkish merger-control rules.

Whether notification is required depends on the transaction and applicable turnover thresholds.

Energy-law approval and competition-law clearance are separate issues.

Foreign buyers should therefore include competition analysis within transaction planning.

23. SPA Protection for Foreign Buyers

The share purchase agreement should contain renewable-energy and storage-specific protections.

Important representations may concern:

• preliminary license;
• generation license;
• storage configuration;
• grid capacity;
• connection rights;
• land;
• environmental approvals;
• construction permits;
• battery warranties;
• EPC obligations;
• financing;
• litigation;
• regulatory compliance.

Known risks may require specific indemnities.

24. Conditions Precedent

Certain issues should be resolved before closing.

Potential conditions precedent include:

• required EMRA procedure;
• grid confirmation;
• lender consent;
• competition clearance;
• critical permit issuance;
• land-right correction;
• release of security;
• third-party contractual consent.

For fundamental regulatory defects, an indemnity may not adequately protect the buyer.

25. 2026 Due Diligence Is Essential

The storage regulatory environment continues to evolve.

TEİAŞ’s February 2026 replacement of the storage connection criteria and its July 2026 replacement of ancillary-service technical criteria demonstrate why investors should not rely on old legal or technical reports.

Due diligence should therefore be refreshed immediately before major investment decisions.

For a foreign investor, the most important principle is simple:

Do not value a solar-plus-storage project according to what it is expected to become. Value it according to the regulatory, grid, land, technical, and contractual rights it actually possesses.

Frequently Asked Questions

1. Can a foreign investor develop a solar plus storage project in Turkey?

Yes. Foreign investors can participate in Turkish renewable-energy projects subject to applicable electricity-market, corporate, investment, land, competition, environmental, grid, and other regulatory requirements.

2. Does a solar plus storage project require an EMRA license?

The regulatory structure depends on the project. Licensed generation generally follows Turkey’s preliminary-license and generation-license framework, while storage is regulated according to its integration and electricity-market function.

3. Is a preliminary license enough to begin electricity generation?

No. A preliminary license primarily enables the project company to complete the development-stage approvals and obligations necessary to progress toward a generation license.

4. What changed for electricity storage projects in 2026?

TEİAŞ replaced its previous storage grid connection and compliance criteria on February 27, 2026. It also replaced the previous ancillary-services technical criteria and testing procedures on July 3, 2026.

5. Can an existing solar plant add battery storage?

Potentially, but the investor must assess licensing, license amendment, grid capacity, technical compliance, connection arrangements, land, permits, and other applicable requirements before installation.

6. Can solar plus storage projects provide ancillary services?

Potentially, subject to applicable market and technical requirements. TEİAŞ maintains specific technical criteria and testing procedures for the use of storage units and facilities in ancillary services.

7. What are the biggest risks when buying a storage-integrated solar project?

Major risks include incomplete preliminary-license obligations, defective grid rights, outdated technical studies, insufficient land rights, unrealistic revenue assumptions, battery degradation, weak manufacturer warranties, lender security, missing permits, and regulatory change-of-control issues.

8. Should the buyer independently verify grid capacity?

Yes. Grid capacity can be one of the most valuable rights associated with the project. The investor should examine the actual TEİAŞ or distribution-level documentation rather than relying solely on the seller’s representations.

9. Does acquiring the project company require EMRA approval?

It depends on the project’s regulatory status, transaction structure, ownership change, and rules applicable at the relevant time. The issue should be analyzed before signing and closing.

10. What should a foreign investor check before investing?

At minimum, the investor should verify EMRA authorization, preliminary-license obligations, storage configuration, grid rights, land, permits, environmental compliance, EPC arrangements, battery warranties, degradation guarantees, software rights, insurance, financing, security, and all required transaction approvals.

Legal Support for Solar Plus Storage Investments in Turkey

Solar-plus-storage investments combine renewable-energy regulation, battery technology, grid access, construction, project finance, land law, environmental compliance, and M&A. The rapid development of Turkey’s storage framework makes current legal and technical due diligence particularly important for international investors.

Fırat Fesih Kaya provides legal assistance to foreign energy companies, infrastructure funds, institutional investors, solar developers, battery manufacturers, project sponsors, lenders, and strategic buyers concerning solar-plus-storage projects, EMRA licensing, TEİAŞ grid connection, storage-integrated generation investments, energy M&A, regulatory due diligence, project finance, SPA negotiations, and renewable-energy disputes in Turkey.

Early legal involvement can help investors determine whether a proposed project is genuinely bankable and whether its grid capacity, storage configuration, licenses, permits, land rights, and revenue assumptions support the valuation requested by the seller or developer.

For a case-specific legal assessment concerning a solar-plus-storage investment, project acquisition, or renewable-energy development in Turkey, you may contact our office.

Phone: +90 312 434 22 22
Mobile: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No: 221, Yıldırım Tower No: 148, 06520 Balgat, Çankaya, Ankara, Turkey