Discover the 2026 legal requirements for rooftop solar projects in Turkey. This guide explains unlicensed generation, consumption requirements, grid applications, roof rights, construction permits, EPC contracts, surplus electricity, financing, and risks for foreign-owned companies.

Rooftop solar projects have become an increasingly attractive investment for foreign-owned factories, warehouses, hotels, shopping centres, logistics facilities, agricultural businesses, offices, and other commercial electricity consumers operating in Turkey.

A properly structured rooftop photovoltaic project can reduce electricity costs, improve energy-price predictability, support corporate sustainability targets, and strengthen compliance with international environmental, social, and governance policies. It may also help export-oriented businesses respond to customer demands concerning renewable electricity, carbon reduction, and supply-chain transparency.

However, installing solar panels on a commercial roof in Turkey is not merely an engineering or procurement project. It requires compliance with electricity market legislation, unlicensed generation rules, grid-connection procedures, construction and zoning regulations, property law, occupational safety requirements, environmental rules, fire-safety standards, and contractual obligations.

The description “unlicensed rooftop solar” does not mean that no administrative approval is required. It generally means that the project may operate without obtaining a preliminary electricity generation license or generation license from the Energy Market Regulatory Authority, commonly known as EMRA. The investor must still complete the applicable connection, project approval, construction, metering, technical acceptance, and settlement procedures.

This 2026 guide explains the main legal requirements, investment structures, application process, contractual risks, and regulatory concerns affecting foreign-owned businesses planning rooftop solar projects in Turkey.

Why Foreign-Owned Businesses Invest in Rooftop Solar

Commercial and industrial consumers generally invest in rooftop solar to generate electricity for their own operational needs.

The main commercial objectives include:

• Reducing purchased electricity costs
• Protecting the business against tariff increases
• Using otherwise idle roof space
• Meeting renewable energy commitments
• Reducing indirect greenhouse gas emissions
• Supporting sustainability reporting
• Improving supply-chain competitiveness
• Satisfying customer and lender ESG requirements
• Increasing the long-term value of industrial property
• Supporting electrification and storage investments

The Ministry of Energy and Natural Resources expressly identifies rooftop and façade solar installations as a means of generating electricity at or near consumption points.

Rooftop projects may be particularly suitable for businesses with high daytime consumption because solar production often corresponds with working-hour electricity demand.

Are Rooftop Solar Projects Licensed or Unlicensed?

Most commercial rooftop solar projects are developed under Turkey’s unlicensed electricity generation regime.

Under this framework, an eligible real person or legal entity may establish a renewable electricity generation facility without obtaining an EMRA preliminary license or generation license, provided that the project satisfies the conditions prescribed by the Electricity Market Law and the Regulation on Unlicensed Electricity Generation in the Electricity Market.

The governing framework includes:

• Electricity Market Law No. 6446
• Regulation on Unlicensed Electricity Generation in the Electricity Market
• Renewable Energy Law No. 5346
• Electricity market connection and system-use rules
• Distribution system regulations
• Metering and settlement rules
• EMRA Board decisions
• Technical project approval requirements
• Zoning and construction legislation
• Occupational health and safety legislation
• Fire-safety and electrical standards

EMRA maintains an official unlicensed-generation page containing the current regulation, application-document lists, connection agreement forms, and related materials.

Can a Foreign-Owned Company Install Rooftop Solar in Turkey?

Yes. A company incorporated in Turkey may generally apply for an unlicensed rooftop solar project even where some or all of its shares are owned by foreign investors.

A Turkish company with foreign shareholders is usually treated as a Turkish legal entity for electricity market purposes. Nevertheless, the project must be established for an eligible consumption facility and structured in accordance with Turkish law.

The foreign-owned business should verify:

• Its corporate authority to make the investment
• Its ownership or lawful use of the building
• Its control over the electricity subscription
• Its legal right to use the roof
• Its eligibility under the unlicensed generation framework
• The grid capacity available at the relevant connection point
• Whether lender or landlord consent is required
• Whether any foreign-investment or security-zone issue applies
• Whether the investment requires group-company approvals
• Whether the project affects existing financing covenants

The foreign parent company cannot normally rely solely on its overseas legal identity to install a Turkish unlicensed project without an eligible local structure and associated consumption facility.

Is a Consumption Facility Required?

As a general rule, the applicant must have at least one electricity subscription or consumption facility under its control.

The Ministry’s official guidance states that persons establishing unlicensed generation facilities must have at least one electricity subscription. Where the consumption facility does not yet exist at the time of application, it must generally be completed by the time the generation facility enters operation.

For a rooftop project, the associated consumption facility is commonly:

• The factory beneath the roof
• A warehouse
• A production plant
• A hotel
• A shopping centre
• A cold-storage facility
• A logistics centre
• A hospital
• A commercial building
• An agricultural processing facility

The company should be able to demonstrate the legal relationship between itself, the electricity subscription, the building, and the rooftop generation facility.

Must the Roof and Electricity Subscription Belong to the Same Company?

Not necessarily, but the structure must be legally secure.

Several arrangements are possible:

Owner-Occupied Building

The foreign-owned company owns the building, controls the roof, and holds the electricity subscription.

This is generally the simplest legal structure.

Leased Building

The company leases the factory or commercial property and holds the electricity subscription.

In this case, the lease agreement should expressly permit:

• Installation of photovoltaic panels
• Structural works
• Roof penetration
• Installation of cabling and transformers
• Access for maintenance
• Connection to the building’s electrical system
• Registration of lender security where necessary
• Continued use of the roof throughout the project life

Third-Party Roof Ownership

The operating company may use a building owned by an affiliate, landlord, organised industrial zone, or another third party.

A separate roof-use agreement, lease amendment, easement, or other legally enforceable arrangement may be required.

The electricity market application should remain consistent with the actual property and consumption structure. Artificial arrangements may create rejection, settlement, or enforcement risks.

Rooftop Ownership and Use Rights

Before an application is submitted, the investor should establish who legally owns and controls the roof.

The review should cover:

• Title deeds
• Lease agreements
• Building management rights
• Condominium records
• Co-ownership rights
• Existing mortgages
• Attachments and injunctions
• Rights granted to other tenants
• Lender security
• Insurance restrictions
• Existing telecommunications equipment
• Roof-access rights
• Maintenance obligations

A company leasing only part of a building may not automatically have the right to install solar panels across the entire roof.

Rooftop Solar in Multi-Owner Buildings

Where a commercial building is subject to condominium ownership or co-ownership, the roof may qualify as a common area.

Installing solar equipment on a common area may require approval under:

• The Condominium Law
• The management plan
• The articles or rules governing the industrial site
• Co-ownership principles
• Existing lease agreements
• Building management decisions

The required voting threshold depends on the ownership structure, the nature of the intervention, and whether the installation materially affects the common property.

Foreign businesses should obtain written and legally valid owner consent before signing an EPC agreement or submitting a connection application.

Structural Suitability of the Roof

A legally available roof may still be technically unsuitable.

The investor should commission a structural engineering assessment covering:

• Dead load
• Wind load
• Snow load
• Seismic conditions
• Roof age
• Corrosion
• Waterproofing
• Existing structural defects
• Panel mounting system
• Maintenance walkways
• Fire-access corridors
• Additional equipment weight

The engineering report should determine whether reinforcement is necessary.

Failure to assess structural capacity may result in:

• Roof damage
• Water leakage
• Business interruption
• Personal injury
• Insurance disputes
• Occupational safety liability
• EPC litigation
• Administrative enforcement

Application to the Grid Operator

A rooftop solar project generally requires an application to the relevant network operator.

Depending on the project location and connection level, this may be:

• The relevant electricity distribution company
• An organised industrial zone holding a distribution license
• TEİAŞ for transmission-level connections

The Ministry confirms that non-hydraulic unlicensed generation applications are made to the relevant distribution company, licensed organised industrial zone, or TEİAŞ where transmission-level connection is requested.

Since October 1, 2023, unlicensed generation applications have been accepted electronically under the applicable procedure, and physical submissions may not be recognised as valid.

Main Application Documents

The required documents depend on the applicant, project capacity, connection level, and relevant network operator.

Typical documentation includes:

• Unlicensed generation application form
• Corporate registration records
• Trade Registry Gazette documents
• Articles of association
• Signature circular
• Tax registration documents
• Shareholding information
• Authorised representative documents
• Consumption subscription information
• Electricity bills
• Title deed or lease documents
• Roof-use consent
• Site plan
• Building documentation
• Single-line diagram
• Photovoltaic technical evaluation form
• Installed-capacity calculations
• Equipment information
• Connection-point information
• Regulatory declarations
• Application-fee receipt

EMRA publishes the applicable list of information and documents required for unlicensed generation applications.

Incomplete, inconsistent, or misleading documentation may lead to the application being rejected.

Grid Capacity Assessment

Ownership of a suitable roof does not guarantee that the requested solar capacity can be connected.

The relevant grid operator assesses:

• Transformer capacity
• Feeder capacity
• Voltage quality
• Short-circuit conditions
• Existing generation capacity
• Existing connection applications
• Protection requirements
• Reverse power-flow risks
• Network reinforcement needs
• Connection-point suitability

The operator may:

• Approve the requested capacity
• Approve a lower capacity
• Require technical modifications
• Require additional network investment
• Reject the application due to insufficient capacity

Foreign-owned businesses should avoid ordering equipment before confirming the legally available connection capacity.

Call Letter for the Connection Agreement

Where the application receives a positive technical assessment, the applicant may receive a call letter inviting it to execute a connection agreement.

The call letter generally identifies:

• Approved electrical capacity
• Connection point
• Connection voltage
• Technical conditions
• Protection requirements
• Project deadlines
• Connection obligations
• Required documents

The call letter is one of the most important legal documents in the development process.

Failure to comply with the deadlines for project approval, agreement execution, construction, or technical acceptance may result in loss of the connection right.

Is a Call Letter Transferable?

A call letter should not be regarded as an ordinary commercial asset that can be freely sold.

It is linked to:

• A specific applicant
• An eligible consumption facility
• A defined generation project
• An approved capacity
• A particular connection point
• Regulatory representations made in the application

A share transfer involving the applicant company, or a transfer of the underlying business or property, should be reviewed before closing.

The investor should determine whether the transaction:

• Requires approval or notification
• Changes the electricity subscriber
• Changes the consumption facility
• Affects application eligibility
• Breaches the call-letter conditions
• Requires network operator consent
• Triggers lender rights
• Creates a risk of cancellation

Electrical and Mechanical Installed Capacity

Rooftop solar projects distinguish between electrical installed capacity and mechanical installed capacity.

Electrical capacity is generally determined by inverter output, while mechanical capacity refers primarily to the total panel capacity.

Current Ministry guidance indicates that the requested mechanical installed capacity of an unlicensed generation facility may not exceed twice its electrical installed capacity.

Oversizing may improve production during low-irradiance periods, but the installed equipment must remain consistent with:

• The grid approval
• The call letter
• The approved project
• Technical acceptance documentation
• Metering records

Unauthorized capacity changes may cause acceptance delays, payment disputes, or disconnection.

Project Approval

After obtaining the relevant connection right, the investor must prepare and submit the technical project for approval.

The project should cover:

• Photovoltaic panel configuration
• Inverter configuration
• DC and AC cabling
• Protection systems
• Earthing
• Metering
• Transformer arrangements
• Fire-safety measures
• Remote monitoring
• Single-line diagrams
• Connection equipment

Construction should not materially deviate from the approved project without obtaining the necessary amendment.

Construction Permit and Zoning Issues

A rooftop solar project may require review under zoning and construction legislation.

The applicable procedure depends on:

• The type of building
• The municipality
• The organised industrial zone
• The scope of structural works
• Whether the installation alters the building
• Whether a transformer or additional structure is constructed
• Whether reinforcement is required
• Whether the roof installation affects occupancy approval

Relevant documents may include:

• Building permit
• Occupancy permit
• Approved architectural project
• Static project
• Roof reinforcement project
• Municipal approval
• Organised industrial zone consent
• Fire department opinion

An electricity connection approval does not legalise an unlawful building or unauthorised roof alteration.

Technical Acceptance

The solar facility cannot lawfully begin regular commercial operation merely because installation has been completed.

It must pass the applicable technical acceptance procedure.

The acceptance review generally examines:

• Compliance with the approved project
• Installed capacity
• Panel and inverter configuration
• Protection systems
• Metering
• Earthing
• Test reports
• Equipment certificates
• Grid connection
• Safety measures

The Ministry publishes guidance concerning acceptance procedures for electricity generation facilities.

Common reasons for refusal or delay include:

• Unapproved equipment changes
• Capacity discrepancies
• Missing test certificates
• Incorrect protection settings
• Metering defects
• Incomplete project documentation
• Construction inconsistent with the approved design

Connection and System-Use Agreements

The project may require:

• A connection agreement
• A system-use agreement
• Metering arrangements
• Settlement registration
• Data communication systems
• Network-use payments

The investor should carefully examine:

• Connection costs
• Network reinforcement costs
• Meter ownership
• Maintenance responsibility
• Curtailment provisions
• Liability for network damage
• Disconnection rights
• Payment obligations
• Technical reporting requirements

Electricity Self-Consumption

The principal commercial benefit of a rooftop solar project is the reduction of electricity purchased from the grid.

Electricity generated and consumed simultaneously at the same site directly reduces grid purchases.

The financial benefit depends on:

• Daytime consumption
• Electricity tariff
• Solar production
• Seasonal demand
• Production schedules
• Weekend operations
• Factory shutdowns
• Equipment efficiency
• Grid-use charges
• Taxes and fees

A company with strong daytime demand may achieve a higher self-consumption rate than a business operating primarily at night.

Surplus Electricity Sales

Where the solar facility produces more electricity than the associated facility consumes, the surplus may be injected into the grid and treated in accordance with the unlicensed generation and settlement rules.

The payment mechanism depends on the applicable regulatory category, tariff, commissioning date, and settlement conditions.

For many projects, the amount of electricity eligible for payment is linked to the consumption of the associated facility. Generation exceeding the legally eligible limit may be transferred to YEKDEM without payment. The Ministry explains the consumption-linked treatment of surplus generation and the limited exception applicable to certain small residential installations.

Foreign-owned businesses should therefore avoid sizing the project solely to maximise annual generation.

The feasibility study should analyse:

• Historical consumption
• Monthly consumption
• Hourly or interval consumption where available
• Expected production
• Seasonal shutdowns
• Planned expansion or contraction
• Energy efficiency investments
• Potential business relocation
• Changes in contracted power

Monthly Settlement

Unlicensed rooftop projects may benefit from monthly settlement between production and consumption, subject to the applicable framework.

The Ministry’s legislation platform publishes the procedures governing settlement between unlicensed production facilities and their associated consumption facilities.

A proper financial model should consider:

• Monthly solar production
• Monthly electricity consumption
• Subscriber category
• Applicable energy price
• Distribution charges
• Taxes
• Settlement deductions
• Unpaid excess generation
• Curtailment
• Metering errors

Projected revenue should not be based on an assumed unrestricted right to sell all generated electricity.

Can the Consumption Facility Be Changed?

Changing the consumption facility may materially affect project eligibility and revenue.

The company should verify whether the replacement facility:

• Is controlled by the same eligible entity
• Has sufficient contracted power
• Has adequate annual consumption
• Is located in an eligible distribution region
• Has existing generation allocated to it
• Can legally be associated with the rooftop project

A change should not be completed without a regulatory assessment and, where necessary, approval or notification to the relevant network operator.

Rooftop Lease Agreements

Where the business does not own the roof, the roof-use agreement should be drafted specifically for a solar project.

It should regulate:

• Exact roof area
• Project duration
• Installation rights
• Access rights
• Cabling routes
• Transformer location
• Maintenance access
• Structural reinforcement
• Waterproofing responsibility
• Damage to the building
• Rent
• Taxes
• Insurance
• Assignment
• Change of control
• Lender step-in rights
• Early termination
• Compensation for unamortised investment
• Removal of equipment
• Roof restoration

A general commercial lease containing no specific rooftop solar provisions may not adequately protect the investment.

What Happens if the Building Lease Ends?

A rooftop project may have an economic life exceeding 20 years, while the building lease may be significantly shorter.

If the lease ends early, the investor may lose:

• Access to the roof
• The associated consumption facility
• The electricity subscription
• The right to operate the panels
• The expected cost savings
• The ability to service project debt

The project agreement should therefore include:

• A lease term matching the investment period
• Renewal rights
• Restrictions on landlord termination
• Compensation for early termination
• Equipment-removal rights
• Rights to continue operating during disputes
• Lender protections

EPC Contract Requirements

The engineering, procurement, and construction agreement should allocate all major regulatory, technical, and commercial responsibilities.

Important clauses include:

• Detailed scope of work
• Design responsibility
• Application assistance
• Project approval responsibility
• Equipment procurement
• Construction schedule
• Technical acceptance
• Grid-connection support
• Performance guarantees
• Production guarantees
• Delay liquidated damages
• Performance liquidated damages
• Defect correction
• Warranty periods
• Spare parts
• Insurance
• Subcontracting
• Compliance with Turkish law
• Occupational safety
• Termination
• Dispute resolution

The description “turnkey” is not sufficient by itself. The contract should expressly state which party bears the risk of:

• Grid rejection
• Lower capacity approval
• Project approval delays
• Structural reinforcement
• Customs delays
• Equipment incompatibility
• Technical acceptance failure

Roof Leakage and Structural Damage

Roof leakage is one of the most common sources of disputes in rooftop solar projects.

The EPC contract should determine:

• Who inspects the existing roof
• Whether the roof warranty remains valid
• Which mounting system will be used
• Who is responsible for penetrations
• Who repairs waterproofing damage
• How pre-existing defects are documented
• Whether the contractor must provide a separate roof warranty

A pre-construction roof-condition report supported by photographs and technical findings can be critical evidence in a later dispute.

Performance and Generation Guarantees

The contractor may guarantee:

• Installed capacity
• Performance ratio
• Annual electricity generation
• System availability
• Equipment efficiency
• Degradation limits

The contract should explain:

• How performance is measured
• Which irradiation data will be used
• How grid outages are treated
• How curtailment is treated
• Whether dust, snow, or shading is excluded
• What compensation applies to underperformance
• Whether testing is independent

A vague production promise may be difficult to enforce.

Equipment Warranties

The investor should review warranties relating to:

• Solar panels
• Inverters
• Mounting systems
• Transformers
• Cabling
• Monitoring systems
• Fire-safety systems
• Storage units, where applicable

Panel warranties frequently include separate:

• Product warranties
• Performance warranties
• Annual degradation commitments

The contract should identify who is responsible for pursuing warranty claims against overseas manufacturers.

Imported Equipment Risks

Foreign-owned businesses may procure panels, inverters, or other equipment through international supply chains.

Risks include:

• Customs delays
• Currency fluctuations
• Sanctions restrictions
• Export controls
• Product certification issues
• Origin documentation
• Warranty enforcement abroad
• Spare-part shortages
• Insolvency of the manufacturer
• Cybersecurity concerns

The supply agreement should allocate responsibility for customs clearance, duties, certification, delivery delays, and replacement equipment.

Fire-Safety Requirements

Commercial rooftop projects must be designed with fire risk in mind.

The technical and legal review should consider:

• Fire-access routes
• Emergency shutdown
• Cable routing
• Arc-fault protection
• Inverter location
• Combustible roof materials
• Fire department access
• Signage
• Emergency plans
• Coordination with building insurers

A system that satisfies electrical connection rules may still create insurance or building-safety problems if fire requirements are ignored.

Occupational Health and Safety

Installation and maintenance involve significant workplace risks, including:

• Work at height
• Electrical hazards
• Falling objects
• Roof collapse
• Fire
• Crane operations
• Adverse weather
• Restricted industrial areas

The employer, contractor, subcontractors, and site operator may have overlapping responsibilities under Turkish occupational health and safety law.

The EPC agreement should not be treated as automatically eliminating the investor’s own statutory obligations.

Insurance

The company should review whether the rooftop project is covered by:

• Construction all-risks insurance
• Erection all-risks insurance
• Third-party liability insurance
• Employer’s liability insurance
• Operational property insurance
• Machinery breakdown insurance
• Business interruption insurance
• Natural disaster insurance
• Cyber insurance

The existing building insurance policy should be updated before construction begins.

The insurer should be informed of:

• Additional roof load
• Electrical equipment
• Fire risks
• Structural works
• Increased property value
• Business interruption exposure

Financing Rooftop Solar

Rooftop projects may be financed through:

• Corporate equity
• Bank loans
• Green loans
• Leasing
• Vendor financing
• Energy service agreements
• Build-operate-transfer structures
• Power-cost-saving arrangements

Lenders may require:

• Security over equipment
• Assignment of receivables
• Bank account pledges
• Insurance assignments
• Share pledges
• Landlord consent
• Direct agreements
• Step-in rights
• Long-term roof rights

The financing period should not exceed the secured period of roof access and building occupation.

Energy Service Company Models

Some businesses prefer not to purchase the system directly. Instead, a third-party investor or energy service company finances and operates the rooftop system.

Potential models include:

• Equipment leasing
• Roof leasing
• Energy performance contracts
• Shared-savings agreements
• Build-operate-transfer arrangements
• Long-term operation contracts

The parties must ensure that the arrangement does not amount to unauthorised electricity supply or trading.

The contract should clearly distinguish between:

• Provision of equipment
• Financing
• Operation and maintenance
• Energy-cost savings
• Electricity sale

A structure that economically constitutes electricity supply may require a different regulatory analysis.

Corporate Power Purchase Agreements

Foreign-owned businesses often seek long-term renewable electricity arrangements described as corporate power purchase agreements.

Where electricity is generated through an unlicensed rooftop facility, the parties must ensure that the contractual structure remains compatible with the self-consumption purpose of the regime.

Potential risks arise where:

• The rooftop producer and consumer are different legal entities
• The producer charges directly for electricity
• The arrangement resembles licensed electricity supply
• The electricity subscription is held by another party
• The facility is not genuinely linked to the consumer’s operations

The agreement should be reviewed under energy market law before execution.

Organised Industrial Zone Projects

Factories located in organised industrial zones may be subject to additional procedures.

The relevant organised industrial zone may:

• Hold a distribution license
• Operate the internal grid
• Review applications
• Issue technical approvals
• Regulate roof installations
• Impose construction rules
• Require management consents
• Apply internal tariff and network procedures

The business should review both national electricity legislation and the organised industrial zone’s internal regulations.

Share Transfers and Corporate Restructuring

A foreign-owned company operating a rooftop project may later undergo:

• Share sale
• Merger
• Demerger
• Intra-group restructuring
• Asset sale
• Factory sale
• Lease transfer

Each transaction should be reviewed for its effect on:

• Electricity subscription
• Consumption facility
• Roof rights
• Connection agreement
• Call letter
• System-use agreement
• Financing documents
• Insurance
• Project eligibility

The rooftop system should not be assumed to transfer automatically with the building or company shares in every structure.

Sale of the Building

If the building is sold, the parties must determine:

• Whether the panels are legally part of the building
• Whether they are movable equipment
• Whether lender security exists
• Whether the connection rights transfer
• Whether the electricity subscriber changes
• Whether the consumption facility remains eligible
• Whether the buyer will assume the EPC and maintenance contracts

The sale agreement should specifically address the solar installation.

Due Diligence When Acquiring a Rooftop Solar Project

A foreign investor acquiring a business with an existing rooftop facility should conduct specialised due diligence.

The review should cover:

• Eligibility of the applicant
• Consumption subscription
• Historical consumption
• Roof ownership
• Lease rights
• Owner approvals
• Structural reports
• Application documents
• Call letter
• Approved capacity
• Connection agreement
• Approved project
• Technical acceptance
• Installed equipment
• Metering
• Settlement
• Surplus payments
• EPC warranties
• Insurance
• Grid charges
• Administrative investigations
• Financing security
• Pending disputes

Common Hidden Risks

Typical hidden risks include:

• The tenant lacked authority to use the roof
• The roof is a common area without valid consent
• The installed capacity exceeds the approval
• The building lacks a valid occupancy permit
• Structural reinforcement was not completed
• The project differs from the approved design
• The electricity subscription belongs to another company
• Consumption has materially decreased
• Excess electricity is not eligible for payment
• Equipment warranties are not assignable
• The building insurer was not notified
• The project is pledged to a lender
• The connection agreement contains unresolved breaches

Administrative Sanctions and Disconnection

Regulatory non-compliance may result in:

• Rejection of the application
• Cancellation of connection rights
• Refusal of project approval
• Refusal of technical acceptance
• Disconnection
• Non-payment for surplus electricity
• Recovery of previous payments
• Transfer of electricity to YEKDEM without payment
• Administrative fines
• Civil liability
• Criminal investigation where false documents or fraud are alleged

Turkey publishes annual administrative fine amounts under Article 16 of the Electricity Market Law; a specific communiqué applies to penalties imposed in 2026.

Challenging a Rejected Rooftop Solar Application

A business whose application is rejected should request the written legal and technical basis for the decision.

Potential remedies may include:

• Correcting missing documents
• Requesting reconsideration
• Objecting to the grid assessment
• Applying to EMRA
• Challenging discriminatory treatment
• Filing an administrative lawsuit
• Requesting a stay of execution
• Filing a contractual claim against a consultant or EPC contractor

The correct remedy depends on whether the dispute concerns an administrative act, regulated network activity, private contract, technical evaluation, or property right.

2026 Compliance Priorities

In 2026, foreign-owned businesses should pay particular attention to:

• Genuine control over the consumption facility
• Valid roof ownership or use rights
• Electronic application requirements
• Grid-capacity limitations
• Mechanical and electrical capacity compliance
• Consumption-linked surplus payments
• Consumption-facility changes
• Structural and fire safety
• Project consistency
• Technical acceptance
• Ultimate beneficial ownership
• Sanctions and equipment-supply risks
• Cybersecurity of monitoring systems
• ESG and carbon-accounting claims

Official distribution company materials continue to publish 2026 unlicensed generation applications, capacity information, and application fees, demonstrating that project procedures remain actively administered at network-operator level.

Practical Legal Checklist

Before starting a rooftop solar investment, a foreign-owned business should:

1. Verify its electricity consumption and subscription.
2. Confirm ownership or long-term use of the building.
3. Obtain legally valid roof rights.
4. Review condominium or co-ownership approvals.
5. Commission a structural assessment.
6. Analyse grid capacity.
7. Submit the electronic connection application.
8. Review the call letter carefully.
9. Obtain project and construction approvals.
10. Negotiate a detailed EPC contract.
11. Arrange construction and operational insurance.
12. Complete technical acceptance.
13. Execute connection and system-use documentation.
14. Verify metering and settlement.
15. Monitor consumption and surplus generation.
16. Maintain regulatory, technical, and safety records.

Frequently Asked Questions

1. Can a foreign-owned business install rooftop solar panels in Turkey?

Yes. A Turkish company with foreign shareholders may generally establish an eligible rooftop solar facility, provided it complies with the unlicensed generation, property, connection, construction, and technical requirements.

2. Does a rooftop solar project require an EMRA generation license?

Most self-consumption rooftop projects may qualify for the unlicensed generation regime and therefore do not require a preliminary license or generation license. Other approvals remain mandatory.

3. Must the company own the building?

No. A tenant may potentially establish a rooftop project, but it must have valid and sufficiently long-term rights to use the roof and must obtain all required owner and management approvals.

4. Is an electricity subscription required?

Generally, yes. The applicant must have an eligible electricity consumption facility or subscription associated with the generation facility.

5. Can the company sell all electricity produced by the rooftop panels?

Not necessarily. The unlicensed model is primarily intended for self-consumption. Payment for surplus electricity may be limited by the consumption of the associated facility.

6. Does the distribution company have to approve the full requested capacity?

No. Approval depends on grid capacity, connection conditions, transformer limitations, and technical suitability. A lower capacity may be offered or the application may be rejected.

7. Is landlord permission sufficient for a leased factory?

Not always. The investor should also check title records, mortgage restrictions, common-area rights, zoning, building permits, insurance, lender consents, and the duration of the lease.

8. What happens if the business moves out of the building?

The relocation may affect the roof rights, electricity subscription, consumption facility, connection arrangements, and financial viability of the project. The lease and project contracts should address this risk.

9. Can another company install panels and sell electricity to the foreign-owned business?

The structure must be reviewed carefully. An arrangement that effectively constitutes electricity supply may fall outside the unlicensed self-consumption framework and may create regulatory risk.

10. What is the greatest legal risk in a rooftop solar investment?

The greatest risk is beginning construction or financing before confirming the applicant’s consumption eligibility, roof rights, grid capacity, project approvals, and contractual protections.

Legal Support for Rooftop Solar Projects in Turkey

Rooftop solar investments require coordinated legal advice covering energy regulation, corporate law, real estate, commercial leasing, zoning, construction, project finance, insurance, occupational safety, and EPC contracting.

A project may appear technically feasible while containing serious legal problems concerning roof ownership, tenant rights, grid capacity, building permits, consumption eligibility, technical acceptance, or surplus electricity payments.

Fırat Fesih Kaya Law Office provides legal assistance to foreign-owned businesses, international manufacturers, logistics companies, industrial consumers, property investors, solar developers, lenders, EPC contractors, and renewable energy funds involved in rooftop solar projects in Turkey.

Our services may include:

• Regulatory feasibility assessments
• Unlicensed generation applications
• Roof ownership and lease reviews
• Rooftop-use agreements
• Condominium and co-owner approval analysis
• EPC contract drafting and negotiation
• Grid connection disputes
• Project due diligence
• Share and asset acquisitions
• Financing and security review
• EMRA applications
• Administrative litigation
• Construction and performance disputes

Early legal review can help prevent connection rejection, invalid roof arrangements, construction delays, technical acceptance problems, and costly disputes with landlords, contractors, network operators, or lenders.

Phone: +90 312 434 22 22
Mobile Phone: +90 532 769 22 22
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. Every rooftop solar project should be assessed according to its specific ownership, consumption, connection, financing, construction, and regulatory circumstances.