On 29 June 2026, the Ministry of Energy and Natural Resources (the “Ministry”) announced the Energy and Carbon Reduction (“EKA”) Support Programme, which aims to support businesses that reduce the carbon intensity of their operations through improvements in energy efficiency.

According to the announcement, applications will be accepted through the Energy Efficiency Support Management System (“EVDES”) between 1 July and 30 September 2026. The Ministry further stated that certain enterprises operating in the manufacturing industry and the buildings and services sectors will be eligible to apply, and outlined the applicable evaluation criteria, the methodology for calculating support amounts, and the procedures governing the reference, implementation, monitoring, and payment periods. In this respect, the Programme appears to constitute a performance-based support mechanism focused on energy efficiency and carbon reduction outcomes.

Following the scoring process, the top ten applications in each sector will be selected for the monitoring phase. Upon completion of the monitoring period, a final assessment will be conducted. Businesses achieving a calculated reduction performance exceeding 70%, as determined under the applicable methodology, may be eligible for a grant of up to 30% of their 2026 energy expenditures, depending on the level of reduction achieved. The maximum support amount has been set at TRY 18,061,775. The Programme envisages a reference period covering January 2023 to December 2025, an implementation and monitoring period covering January to December 2026, and a payment period commencing in July 2027 and thereafter.

The Ministry expressly states in the announcement that applications will be assessed in accordance with the Implementation Procedures and Principles on the Energy and Carbon Reduction Support Programme (the “Procedures and Principles”). As such, the EKA Support Programme should arguably not be viewed merely as a standalone incentive scheme applicable to a particular application period, but rather as part of the broader regulatory and institutional framework that has evolved over many years in the field of energy efficiency.

Regulatory Framework of the EKA Programme

The principal rules governing the implementation of the Programme are set out in the Procedures and Principles. These provisions address, among other matters, application requirements, evaluation criteria, monitoring procedures, payment mechanisms, and circumstances in which support payments may be reclaimed.

The legal basis of the Procedures and Principles is found in Article 34 of the Regulation on Increasing Efficiency in the Use of Energy Resources and Energy (the “Regulation”). The relevant provision authorises the Ministry to prepare and publish the procedural framework relating to training, certification, authorisation, and support mechanisms in the field of energy efficiency. It therefore appears that the operational rules governing the EKA Programme have been established pursuant to this delegated authority.

The Regulation also serves as the foundation for the authorisation regime applicable to entities operating in the energy efficiency sector. In this context, Procedures and Principles Governing the Issuance of Certificates of Authorization to Institutions and Organizations Providing Energy Efficiency Services regulate the entities entitled to provide energy efficiency services and the conditions under which such services may be rendered. Pursuant to these rules, legal entities satisfying the prescribed requirements may obtain a five-year authorisation certificate enabling them to operate as an Energy Efficiency Consultancy Company (“EVD”).

The statutory basis of this authorisation framework can be traced to Article 5 of the Energy Efficiency Law No. 5627 (the “Law”). This provision defines the roles and responsibilities of universities, professional chambers, authorised institutions, and EVD companies within the energy efficiency ecosystem. It also sets out their functions concerning energy audits, consultancy services, energy efficiency projects, and related activities. Furthermore, the Authorisation Agreement for Institutions, annexed to the relevant authorisation procedures, expressly refers to Article 5 of the Law and emphasises that activities are to be carried out in compliance with the applicable energy efficiency legislation.

Viewed from this perspective, the legal infrastructure underpinning the EKA Programme extends beyond the Ministry’s announcement itself. Rather, it appears to rest upon a multi-layered regulatory framework comprising Law No. 5627, the Regulation, and the secondary rules adopted pursuant thereto. While the Law establishes the fundamental authority and institutional framework, the Regulation shapes the practical application of energy efficiency policy, and the Procedures and Principles provide the Programme’s operational rules. The Ministry’s announcement may therefore be seen as the final step that operationalises this regulatory framework for a specific application period.

Operational Framework of the EKA Programme

The implementation of the Programme appears to be supported not only by legal rules but also by a range of technical and administrative mechanisms. Application File Formats, Monitoring File Formats, Calculation Methodologies, and Sample Calculation Documents are among the core instruments used to determine how energy efficiency and carbon reduction performance will be measured. The assessment of both application-stage data and monitoring-period results in accordance with these methodologies constitutes a significant element of the Programme’s performance-based structure.

In practice, businesses may also seek technical support from Energy Efficiency Consultancy Companies in relation to the preparation of energy performance analyses, energy intensity assessments, and carbon reduction studies. This suggests that the EVD system functions not merely as a standalone authorisation mechanism but also as one of the institutional structures contributing to the implementation of broader energy efficiency policies.

A review of the eligibility requirements set out in the Procedures and Principles further indicates that participation in the Programme is contingent upon compliance with a number of obligations. Requirements such as maintaining up-to-date EVDES records, appointing an energy manager, uploading the necessary documentation to the system, and, for certain enterprises, holding an ISO 50001 Energy Management System certificate, appear to be linked to obligations arising under various regulatory instruments. Accordingly, the Programme does not seem to be limited to a grant application process alone but rather forms part of a wider framework encompassing energy management and regulatory compliance obligations.

The support process itself appears to consist of several consecutive stages. Following the submission of applications, a preliminary evaluation is carried out, after which a limited number of enterprises from each sector are admitted to the monitoring phase. A final evaluation is then conducted upon completion of the monitoring period. Accordingly, entitlement to support is influenced not only by the information submitted during the application stage but also by the actual performance achieved during the monitoring period. In particular, monitoring-period data and the monitoring file prepared on the basis of such data are likely to serve a critical role in the final assessment process.

Against this backdrop, businesses considering participation in the Programme may wish to view the application process as extending beyond the mere preparation of documentary requirements. The accuracy of reference-period data, the sustainability of the performance improvements achieved during the monitoring period, and compliance with the relevant regulatory obligations may all constitute important aspects of a successful application strategy.

The Programme also appears to incorporate a range of audit and verification mechanisms. These include the review of application documents, on-site inspections where deemed necessary, verification of monitoring-period data, and post-payment controls. Collectively, these measures form an integral part of the Programme’s oversight framework.

In addition, where irregularities, misrepresentations, or non-compliance with applicable legislation are identified, not only the specific rules governing the EKA Programme, but also other areas of legislation may become relevant depending on the circumstances of the case. Situations involving false documentation or inaccurate records could potentially give rise to considerations under Article 359 of the Tax Procedure Law, while matters concerning the recovery and collection of public support payments may, in certain cases, fall within the scope of Law No. 6183 on the Procedure for the Collection of Public Receivables.

Concluding Remarks

Taken together, the foregoing considerations suggest that the EKA Support Programme may be viewed not merely as a grant scheme announced for a specific period, but as part of a broader legislative and institutional architecture established in the field of energy efficiency. An examination of the underlying Law, Regulation, and implementing rules indicates that energy management, data collection, performance monitoring, and authorisation mechanisms have been designed to operate in close connection with the support process.

Ultimately, the EKA Support Programme may be regarded as one of the more recent examples of the integration of various regulatory and implementation tools developed under Turkey’s energy efficiency framework. Accordingly, a comprehensive assessment of the Programme's legal and technical dimensions, taking into account not only the announcement itself but also the relevant legislation, implementation rules, and related compliance obligations, is likely to be important for the effective management of the application and implementation process.

@Zeynep EMİROĞLU