Turkish Energy and Natural Resources Law: A Guide for Foreign Investors

Turkey regulates energy through sector-specific statutes rather than one code, and almost every activity — from exploration to retail — needs a licence from the Energy Market Regulatory Authority (EPDK/EMRA) or, upstream, from the General Directorate of Mining and Petroleum Affairs (MAPEG). This guide explains how the petroleum, LPG, electricity, nuclear and mining sectors are governed under Turkish energy law and what foreign companies need to know before they invest or operate. Figures here reflect 2025–2026 data; the underlying rules change often through secondary legislation, so check them with a Turkish lawyer on the relevant date.

How Turkey regulates energy and natural resources

Energy and natural resources are among the most tightly regulated areas of Turkish law. Almost every commercial activity — exploration, production, import, export, storage, transmission, distribution and retail — requires a licence, and most sit under the supervision of the Energy Market Regulatory Authority (EPDK / EMRA). For foreign investors, this means the legal questions are rarely just commercial; they are licensing, administrative and regulatory questions decided by specialised agencies and administrative courts.

The sector is governed by a layer of sector-specific statutes rather than a single energy code. The most important are:

• Petroleum Law No. 6491 — upstream oil and gas exploration and production rights.
• Electricity Market Law No. 6446 — generation, transmission, distribution, trading and (since 2022) electricity storage.
• Natural Gas Market Law No. 4646 — import, transmission, storage, distribution and sale of natural gas.
• LPG Market Law No. 5307 — the liquefied petroleum gas (autogas and bottled gas) market.
• Renewable Energy Law No. 5346 (YEK) — incentives and support for renewable electricity.
• Nuclear Regulation Law No. 7381 (2022) and Nuclear Power Plant Law No. 5710 (2007) — the construction, operation and safety regulation of nuclear plants.
• Mining Law No. 3213 — mineral rights, including boron and other reserves.

General Turkish private and procedural law applies on top of these — the Turkish Code of Obligations (TBK No. 6098) for contracts, the Turkish Commercial Code (TTK No. 6102) for company and corporate matters, and the Code of Civil Procedure (HMK No. 6100) and the Administrative Procedure Law for disputes. Where smuggling or fuel-adulteration offences arise, the Anti-Smuggling Law No. 5607 and the Turkish Criminal Code (TCK No. 5237) come into play.

Sector, law and regulator at a glance

Can foreign investors enter the Turkish energy market?

Yes. Under the Foreign Direct Investment Law No. 4875, foreign investors are treated equally with Turkish investors and may generally hold up to 100% of a Turkish company across the petroleum, electricity, gas and LPG markets and most mining activities, subject to the relevant licensing regime. There is no blanket foreign-ownership cap on energy generation. The practical gateway is almost always a Turkish company or special-purpose vehicle that holds the licence, plus work and residence permits for any foreign personnel.

A few resources are concentrated under state control — most notably boron — so foreign involvement there is through supply, processing and downstream commercial arrangements rather than ownership of reserves. For an investment route, foreign investors should weigh the investment incentive certificate regime, which can bring customs-duty and VAT exemptions and other support for qualifying energy projects; the exact benefits depend on the project, region and current incentive decree.

The petroleum (oil) sector

Upstream oil and gas activity in Turkey is governed by the Petroleum Law No. 6491 and its implementing regulation, with the General Directorate of Mining and Petroleum Affairs (MAPEG) as the competent authority. A company that wants to explore or produce hydrocarbons must hold the relevant exploration or operation (production) licence, and many ancillary activities require separate permits.

Legal work in the oil sector typically covers:

• Application for and follow-up of exploration and operation licences and research permits.
• Representation before regulatory bodies such as MAPEG and EPDK.
• Production, import, export, domestic and foreign sales, and distributorship arrangements.
• Compliance with the Petroleum Law and its regulations, and representation in administrative and judicial proceedings.
• Transfer of petroleum rights, return of guarantees, state shares, use rights and removal of facilities.
• Taxation, capital and profit transfers, and import/export of materials.
• Permission procedures for offshore exploration, contractor agreements and export permits for drill cuttings and samples.
• Permits for the employment of foreign personnel (work permits under Law No. 6735 / residence under Law No. 6458).

Downstream — refining, distribution and retail of fuel — is licensed by EPDK under the Petroleum Market Law No. 5015. Distributorship and dealership disputes between licence holders are common and frequently turn on both the licensing regime and contract law under the TBK No. 6098. We handle distributorship and dealership contract disputes, and where money is owed, recovering unpaid receivables from supply or dealership contracts through Turkish enforcement proceedings.

Fuel adulteration and smuggling cases

One of the most serious risks for fuel distributors and station operators is a criminal investigation for adulterated or untaxed fuel. Turkey uses a national marker system: diesel and other fuels must contain an approved chemical marker at valid levels. During inspections at petrol stations, samples are taken from the pumps and the connected tanks.

If the marker level is found to be invalid — and witness samples are properly taken and recorded in sample-collection protocols, sealing protocols and national marker detection protocols — the customs and trade authorities' smuggling and intelligence directorate can refer the matter for prosecution. The fuel can be seized by written order of the Chief Public Prosecutor's Office, and that seizure is then submitted for approval to the Criminal Judgeship of Peace (Sulh Ceza Hâkimliği). If an expert report classifies the seized fuel as an "illegal product", a prosecution follows under the Anti-Smuggling Law No. 5607, often alongside provisions of the Turkish Criminal Code (TCK No. 5237) and the Criminal Procedure Code (CMK No. 5271).

These cases combine technical evidence (sampling chain of custody, expert reports) with criminal defence. We provide criminal defence in fuel-smuggling and adulteration cases, scrutinising whether samples and protocols were lawfully obtained and challenging the expert findings where appropriate. Outcomes always depend on the specific facts and evidence.

LPG (autogas and bottled gas)

LPG — known locally as tüpgaz — has been used in Turkey since 1960 for cooking, hot water, heating, industrial drying and lighting, and as autogas for an estimated 4.6–5 million vehicles. Turkey is the largest autogas market in Europe, and autogas accounts for a large share of the passenger-car fleet (the sector is targeting around 40%). LPG is a flammable mixture of roughly 70% butane and 30% propane, derived from crude oil or natural gas, stored in steel tanks and odorised so leaks can be detected.

The market is regulated by the Liquefied Petroleum Gas (LPG) Market Law No. 5307 (in force from 2 March 2005) and the LPG Market Licensing Regulation, both supervised by EPDK. Licensing covers distribution, transportation, autogas dealership, storage, manufacturing, filling, and the inspection, repair and maintenance of LPG tanks.

Typical legal services in the LPG sector include:

• Application for and follow-up of LPG market licences (distribution, storage, autogas dealership and others).
• Advising on the reporting obligations of licence holders to EPDK.
• Compliance for filling, storage and tank inspection/maintenance activities.
• Resolving disputes arising during supply, storage, transportation and use of LPG, including dealership contract disputes under the TBK No. 6098 and, where supply invoices go unpaid, enforcing payment under Turkish law.

The electricity sector

Turkey's electricity supply draws on coal, renewables and natural gas. In 2025, coal was the single largest source at about 34%, renewables (hydro, wind, solar, geothermal and biomass together) supplied roughly 43% — with wind and solar combined overtaking hydropower for the first time — and natural gas fell to around 22%. The fossil share, about 55%, was the lowest since 1993. The mix shifts year to year, but the direction of travel is clear: gas down, renewables up. Electricity is unusual because it is both a final product and an input to every other sector, it cannot easily be stored, and it must be produced and delivered continuously.

The market was liberalised and partly privatised from the 1990s onward, producing entities such as Türkiye Elektrik A.Ş. (TEAŞ) and Türkiye Elektrik Dağıtım A.Ş. (TEDAŞ), and later an unbundled structure of generation, transmission (TEİAŞ), distribution and trading companies. The framework today is the Electricity Market Law No. 6446, administered by EPDK.

The licensing path for a power project

Most generation needs a licence under the Electricity Market Licensing Regulation. The usual route is a pre-licence stage (during which the company secures site rights, permits and a connection agreement with TEİAŞ or the relevant distribution company for capacity allocation) followed by the generation licence itself. Securing land, site rights and permitting is itself a substantial workstream — see our land acquisition, site rights and permitting for power plants and mining sites.

How renewable support actually works

Renewable generation is supported under the Renewable Energy Law No. 5346 (YEK). The feed-in mechanism, YEKDEM, was redenominated into Turkish lira for plants commissioned from 1 July 2021 (with a quarterly escalation formula and, for some sources, a US-dollar cap), replacing the older US-dollar tariffs. Large-scale capacity is now allocated mainly through competitive YEKA auctions, and a guarantee-of-origin (YEK-G) scheme lets generators certify and sell the "green" attribute of their electricity separately. Energy storage and hybrid plants have also been brought into the Law No. 6446 framework in recent years.

Legal services in the electricity sector commonly include:

• General regulatory advice on the Electricity Market Law and EPDK secondary legislation.
• Assistance in obtaining pre-licences, generation and supply licences, unlicensed-generation approvals and connection agreements.
• Advice on the construction, acquisition and transfer of power plants (including renewables and YEKA projects), and share and asset transfers and power-plant acquisitions under the TTK No. 6102.
• Legal and regulatory due diligence on energy projects and project finance.

Nuclear energy in Turkey

Nuclear energy is produced by splitting heavy atomic nuclei (fission) or fusing light nuclei (fusion); the energy released from these reactions is what powers nuclear plants. Globally, nuclear supplies a significant share of electricity in several countries — France, for example, has historically generated around three-quarters of its electricity from nuclear, with the United States, Japan and others relying on it to varying degrees.

Turkey's flagship project is the Akkuyu Nuclear Power Plant in Mersin. Under an intergovernmental agreement between Turkey and the Russian Federation signed on 12 May 2010, the project company Akkuyu Nükleer A.Ş. was established to build and operate the plant on a build-own-operate basis. As of 2026, Unit 1 is in the commissioning phase — dummy fuel has been loaded and systems are being tested — with first power targeted for 2026, while Units 2–4 remain under construction. A further plant has been discussed for Sinop.

Legal work here is highly specialised, covering intergovernmental and project agreements, NDK licensing and safety authorisations, environmental permitting and long-term electricity purchase arrangements.

Natural resources and mining: boron (bor)

Beyond hydrocarbons, Turkey holds globally significant mineral reserves, the most strategically important of which is boron (bor). Boron minerals are natural compounds containing boron oxide (B2O3); they are physically enriched and then refined into chemical boron compounds used in glass, fibreglass, ceramics, agriculture and detergents — the large majority of demand — with the remainder in nuclear applications, defence, fuels, polymers, nanotechnology, automotive, metallurgy and construction.

Turkey holds roughly 73% of the world's boron reserves and is a leading producer of boron compounds, meeting a substantial part of global demand. Boron is a state resource: exploitation is concentrated under state control (Eti Maden), so private and foreign involvement tends to take the form of supply, processing and downstream commercial arrangements rather than ownership of reserves.

Mineral rights more generally are governed by the Mining Law No. 3213, administered by MAPEG, covering exploration and operation licences, royalties (state share), and environmental and permitting compliance. Every sizeable mining or energy project also runs through the environmental impact assessment (ÇED / EIA) regime, which is frequently the practical bottleneck for getting a site into production.

How Lexin Legal helps foreign energy investors

Energy and natural resources projects in Turkey involve overlapping licensing, administrative, corporate and sometimes criminal questions — usually conducted in Turkish, before specialised regulators and courts. We act for foreign companies and investors in English, bridging that gap.

Our energy and natural resources work includes:

• Licensing and permit applications and follow-up before EPDK, MAPEG and NDK across the oil, gas, LPG, electricity and nuclear markets.
• Regulatory compliance and representation in administrative and judicial proceedings.
• Transactional support — joint ventures, share and asset transfers and power-plant acquisitions and project documentation under the TTK No. 6102 and TBK No. 6098.
• Criminal defence in fuel-smuggling and adulteration cases under the Anti-Smuggling Law No. 5607.
• Company and energy-SPV set-up, plus work-permit support for foreign personnel and investors.

For a deeper dive on upstream oil and gas, see our comprehensive guide to Turkish energy, oil and gas. To discuss a specific project, contact us. Every matter is reviewed by a qualified Turkish lawyer, and outcomes depend on the facts and the law in force at the time.

Frequently asked questions