Short answer
A licensed solar project in Türkiye runs on two clocks at once. Under the Electricity Market Licence Regulation (Elektrik Piyasası Lisans Yönetmeliği), Official Gazette 02.11.2013 / 28809, Article 17(1), the pre-licence holder must complete a defined set of items within the pre-licence period: site ownership or use rights, finalised master and implementation zoning plan approvals, preliminary or final project approval, the connection agreement application to TEİAŞ or the distribution company, the decision required under the EIA Regulation, the building permit or an equivalent document, and the TEİAŞ solar contribution-share agreement where one is owed. Separately, the construction period and the facility completion date are written into the generation licence, and the construction period is set by Board decision and published on EPDK’s website (Article 23(3)(a)); the periods currently in force are set by EPDK Board Decision No. 13131-2 of 26.12.2024, Official Gazette 29.12.2024 / 32767. Either clock, missed, is a licence problem rather than a construction problem.
Scope of this page: licensed, grid-connected, ground-mounted and floating solar generation.
The permit set and what triggers each item
| Item | Requirement | Provision |
|---|---|---|
| Site rights | Ownership, or acquisition of ownership or use rights where the site is not owned by the pre-licence holder | Licence Regulation Art. 17(1)(a) |
| Zoning | Master and implementation zoning plan approvals must become final | Art. 17(1)(b) |
| Project approval | Preliminary or final project approval obtained | Art. 17(1)(c) |
| Grid connection | Connection agreement application made to TEİAŞ or the relevant distribution company | Art. 17(1)(ç) |
| EIA | The decision required under the EIA Regulation obtained | Art. 17(1)(e) |
| Building permit | Building permit, or the document that takes its place, submitted | Art. 17(1)(f) |
| Contribution share | Solar contribution-share agreement signed with TEİAŞ where the project is liable | Art. 17(1)(g)(3) |
| Floating solar on state water bodies | Lease agreement with DSİ for floating units, or units on canal surfaces or between the maximum and operating water levels of a reservoir | Art. 17(1)(g)(2) |
| YEKA projects | Suitability letter from the General Directorate of Energy Affairs confirming the conditions of the YEKA Regulation | Art. 17(1)(ğ) |
The EIA route itself is set by project area, not by installed power: under the EIA Regulation (Official Gazette 29.07.2022 / 31907, as amended 05.03.2026 / 33187), a ground-mounted solar plant with a project area of 25 ha and above requires a full EIA Report (Annex-1, item 43), while 7.5 ha and above requires a Project Information File (PIF) (Annex-2, item 41). For floating plants the thresholds are 2 ha and above for Annex-1 and up to 2 ha for Annex-2.
Deadlines on amendments and on the construction period
| Subject | Period or obligation | Provision |
|---|---|---|
| Document review of a pre-licence or licence amendment application | 10 working days; 15 working days to close deficiencies; 10 working days to re-review | Licence Regulation Art. 18(2)(b) and Art. 24(2)(b) |
| EIA application after an amendment changing capacity or installed power | Evidence of application submitted to EPDK within 45 days of notification of the Board decision or the service unit action | Art. 18(5)(b) |
| Installed power increase on a renewables pre-licence | Not permitted; mechanical capacity amendment is possible on the conditions in Art. 18(6) | Art. 18(5), Art. 18(6) |
| Pre-licence period extension | Possible only within the force majeure grounds in Article 35; for YEKA pre-licences, with the Ministry’s favourable opinion | Art. 18(3) |
| Conclusion of a licence application | Assessment completed within 45 days and submitted to the Board | Art. 23(1) |
| Effect of incomplete pre-licence obligations | The licence application is rejected by Board decision if any pre-licence obligation was not completed in time | Art. 23(2)(a) |
| Construction period | The construction period and facility completion date are entered in the generation licence; the period is set by Board decision and published on EPDK’s website | Art. 23(3)(a); Board Decision 13131-2, OG 29.12.2024 / 32767 |
Carrying the EIA commitments into construction
An EIA Positive decision is not the end of the environmental file. The Ministry monitors, controls and inspects whether the commitments in the final EIA report or the PIF are met, and checks the project progress reports produced during the construction period (EIA Regulation Article 18(1)). A project progress report records construction-period developments at the intervals set by the commission (Article 4(1)(ff)). Where a project within the EIA scope starts work without an EIA Positive decision, activities are stopped without a grace period and the stop order is not lifted until the decision is obtained (Article 19(1)(a)). An EIA Positive decision also lapses if the investment does not start within five years absent force majeure (Article 14(5)). For a lender, these are the provisions that connect construction supervision to permit validity.
Projects acquired from another developer
Where a project changes hands, the new owner must submit the transfer documents, a declaration that the final EIA report or PIF and its annexes are under its commitment, the notarised signature circular and the approved Trade Registry Gazette to the provincial directorate within 90 calendar days; the previous owner’s commitments and obligations pass to the new owner automatically from the transfer date (EIA Regulation Article 21). On the licence side, the pre-licence obligations in Article 17(1) remain tied to the pre-licence period, so a project acquired mid-stream inherits the remaining time rather than a fresh period.
What Enpark does
Enpark is an environmental and energy consultancy founded in 2012 in Ankara, holding EIA competency certificate No. 222 (issued 09.05.2025, four years) and environmental consultancy competency certificate No. 217503132.2.1 (valid until 30 April 2028). The work covers site selection and permit feasibility, the environmental assessment route, land securing and easement or lease negotiation, management of the permit and deadline calendar, monitoring of contractor programmes against the commitments in the EIA report, provisional and final acceptance files, and periodic progress and risk reporting for investors and lenders, including on projects developed by another party. More than 140 solar, wind and geothermal power plant projects and more than 380 client companies and institutions are on record. For financial institutions and foreign investors the scope has also included ESIA, environmental and social management plans, business plans, financial feasibility studies, regulatory, environmental and financial risk assessments, technical reviews and due diligence; the applicable environmental and social framework is set by the lender’s own requirements and differs from bank to bank, so the scope is settled during project financing. Ecology and ornithology field studies are carried out by specialist subcontractors. Correspondence is in English and Turkish.
Turkish-language counterpart of this page: GES Proje Yönetimi. Related: Güneş Enerjisi Santrali Proje Geliştirme (in Turkish) · Environmental Impact Assessment Regulation — full English translation · About Enpark.
Other services in English: Environmental Impact Assessment (EIA) in Türkiye · Environmental permits and licences in Türkiye.
Frequently asked questions
Which clock governs a solar project — the pre-licence or the construction period?
Both, in sequence. The items in Article 17(1) of the Licence Regulation must be completed within the pre-licence period, and a licence application is rejected if any of them was not (Article 23(2)(a)). Once the generation licence is issued, the construction period and the facility completion date written into it govern, and that period is set by Board decision and published by EPDK (Article 23(3)(a)).
Can the installed power of a licensed solar project be increased?
Not on a renewables-based pre-licence: Article 18(5) of the Licence Regulation states that no electrical installed power increase may be made for pre-licences based on renewable energy sources. A mechanical capacity amendment may be approved where the site boundary is not exceeded, the total electrical installed power recorded in the pre-licence does not change, and the technical assessment by the General Directorate of Energy Affairs is favourable (Article 18(6)).
Is a new EIA needed when capacity changes?
Where a pre-licence is amended for a change in mechanical capacity or electrical installed power, evidence that an application was made to the relevant authorities for the decision required under the EIA Regulation must reach EPDK within 45 days of notification of the Board decision or the service unit action (Licence Regulation Article 18(5)(b)). Whether a new EIA route applies is then determined by the EIA Regulation thresholds, which for solar are set by project area.
Does the EIA threshold depend on installed power?
No. For solar plants the EIA Regulation sets the thresholds by project area — 25 ha and above for an EIA Report and 7.5 ha and above for a PIF for ground-mounted plants, with separate 2 ha thresholds for floating plants (Annex-1 item 43 and Annex-2 item 41, as amended on 05.03.2026).
Can an investor appoint a technical manager for a project developed by someone else?
Yes. Nothing in the Licence Regulation ties the permitting and reporting work to the original developer; the obligations attach to the licence holder. On the environmental side, the commitments in the final EIA report pass to a new project owner automatically from the transfer date (EIA Regulation Article 21), which is what makes an incoming review of the permit, decision, connection and land documents the first step on an acquired project.
What is needed for floating solar on a state water body?
A lease agreement with DSİ must be in place for floating plants, and for solar units on canal surfaces or in the area between the maximum and operating water levels of a reservoir (Licence Regulation Article 17(1)(g)(2)).
Official sources
- Electricity Market Licence Regulation (Elektrik Piyasası Lisans Yönetmeliği), Official Gazette 02.11.2013 / 28809, as amended — mevzuat.gov.tr
- EPDK Board Decision No. 13131-2 of 26.12.2024 on construction periods, Official Gazette 29.12.2024 / 32767 — epdk.gov.tr
- Environmental Impact Assessment Regulation (ÇED Yönetmeliği), Official Gazette 29.07.2022 / 31907; amendments Official Gazette 26.06.2025 / 32938 and 05.03.2026 / 33187 — mevzuat.gov.tr
- Renewable Energy Resource Areas Regulation (Yenilenebilir Enerji Kaynak Alanları Yönetmeliği), Official Gazette 09.10.2016 / 29852 — mevzuat.gov.tr
Unofficial English rendering of the Turkish provisions cited. Only the Turkish text published in the Official Gazette is legally binding. Author: Can Cihan Yılmaz, Managing Partner.