1) Why storage has become the “second engine” of renewable projects
Battery Energy Storage Systems (BESS) are no longer an optional add-on for solar (GES) and wind (RES) projects in Turkey. They are increasingly treated as a system flexibility asset—and Turkey’s regulatory framework has been evolving quickly to (i) integrate storage into licensed generation, (ii) regulate independent storage, and (iii) define how storage interacts with settlement, ancillary services, and support mechanisms.
From an investor and lender perspective, storage reshapes three fundamentals:
- Connection and dispatch reality: storage can shift energy in time, smooth intermittency, and support system needs.
- Revenue stacking: beyond energy sales, storage can potentially monetize balancing and ancillary services—if your configuration and market participation are compliant.
- Compliance exposure: the more value storage creates, the more sensitive your project becomes to metering, data reporting, availability (“ready to operate” status), and settlement rules.
This guide focuses on storage-integrated electricity generation facilities (depollamalı elektrik üretim tesisleri) and the newer regulation packages affecting storage activities in Turkey—what has changed, what is bankable, and what triggers disputes.
2) The regulatory backbone: where storage rules “live”
2.1 The dedicated Storage Regulation (2021)
Turkey introduced a dedicated secondary framework titled the Regulation on Storage Activities in the Electricity Market, published in the Official Gazette on 9 May 2021 (No. 31479). (emo.org.tr)
The regulation’s purpose is to set the procedures and principles for establishing electricity storage units/facilities, connecting them to the transmission or distribution system, and using them in market activities under the Electricity Market Law. (LEXPERA)
Importantly, the regulation excludes pumped-storage hydroelectric plants and UPS systems installed for use during power cuts from its scope—so most utility BESS projects fall inside the storage regime, while certain back-up systems do not. (LEXPERA)
2.2 A major change package effective 1 January 2026 (Official Gazette No. 33122)
A comprehensive set of amendments was published in the Official Gazette dated 29 December 2025 (No. 33122), and the relevant storage-regulation amendment enters into force on 1 January 2026. (LEXPERA)
This package does not only “tweak” storage rules—it introduces new definitions, clarifies settlement treatment, adds annexed connection configurations, and aligns the storage regime with balancing/settlement and renewable support logic. (LEXPERA)
3) Key concepts you must get right: storage-integrated generation vs integrated storage vs independent storage
In Turkish regulatory practice, “storage” can appear in multiple legal architectures. Confusing them is one of the fastest ways to break bankability.
Model A — Storage inside an existing licensed generation plant (co-located BESS)
EMRA has emphasized (in public communications) that electricity storage facilities built within a licensed power plant are included in the plant’s license. (Anadolu Ajansı)
Practically, this model is common for RES/GES developers who want to add BESS for flexibility and market optimization.
Model B — Storage at a consumption facility (behind-the-meter)
EMRA’s public explanation also notes that storage facilities at an electricity consumption facility may be treated as license-exempt. (Anadolu Ajansı)
This is relevant for industrial users installing storage to optimize tariffs and manage demand peaks.
Model C — Independent (stand-alone) storage connected to the grid
Stand-alone storage is regulated as a market activity connected to licensing frameworks. EMRA’s public explanation indicates a supply license requirement for independently built storage facilities, with a minimum storage threshold of 2 MW in that context. (Anadolu Ajansı)
Model D — Storage associated with license-exempt generation (newer rules)
The 29 December 2025 amendment explicitly introduced the concept of storage established by license-exempt generation facilities and allowed storage at certain license-exempt plants that have a call letter and are subject to set-off rules. (LEXPERA)
This model is especially sensitive because it directly affects how surplus energy is treated for payment purposes (explained in Section 6).
4) What changed in the 2025/33122 amendment: the “headline” legal impacts
The 33122 amendment does several things that matter immediately for investors and operators:
4.1 Storage becomes formally available for certain license-exempt plants
The amendment adds a definition referencing storage set up by license-exempt generation and states that license-exempt plants that received a call letter and apply set-off under the license-exempt regulation can establish a storage facility—subject to satisfying specific conditions of the license-exempt regulation. (LEXPERA)
4.2 “No payment” rule for certain energy discharged from storage (license-exempt context)
The amendment introduces a strict settlement/economic outcome:
- If energy is injected into the grid from storage at those eligible license-exempt plants, no payment is made for the portion of surplus energy that is attributable to storage discharge after set-off.
- If the discharged amount from storage cannot be identified, no payment is made for the entire surplus energy.
- That energy is treated as produced by the YEKDEM participant designated supplier and counted as a free contribution to YEKDEM. (LEXPERA)
This is a high-impact rule for business models that hoped to monetize battery arbitrage under license-exempt generation. It means you must design metering and operational logic carefully, and you must not build a financial model on “selling stored surplus” where the regulation removes payment.
4.3 “Ready-to-operate” concept for storage units inside storage-integrated generation
The amendment defines the “ready-to-operate” status (emre amade olma) of storage units in storage-integrated generation facilities as being operable in line with the connection configuration in Annex-1. (LEXPERA)
In practice, this pushes projects to treat availability and proper configuration as compliance items, not just technical performance.
4.4 New connection configuration annexes
The amendment adds multiple annexes (including new Annex-1 variants, Annex-2, and Annex-3 variants) and states that the connection of storage units in storage-integrated generation and integrated storage is made according to the relevant annexed configurations. (LEXPERA)
Why this matters: disputes often arise from mismatches between “as built” configuration, grid operator expectations, and the configuration defined in regulations/annexes—especially when settlement or eligibility depends on it.
4.5 Participation in ancillary services and the balancing power market
The amendment states that storage units established under the relevant article can participate:
- in ancillary services if they satisfy the required conditions, and
- in the balancing power market if they qualify as a balancing unit,
through the generation facility’s associated settlement unit(s). (LEXPERA)
This is a key legal doorway for “revenue stacking,” but it also means your market participation must be structured through the correct settlement identity and compliance program.
4.6 Priority assumptions for injection/withdrawal when both generation and storage operate
The amendment sets a rule of presumption for any settlement period in storage-integrated generation / integrated storage facilities:
- If there is grid withdrawal, it is assumed that the energy is first withdrawn by the storage facility (if storage withdrawal exists in that settlement period).
- If there is grid injection, it is assumed that the energy is first injected by the storage facility (if storage injection exists in that settlement period). (LEXPERA)
This kind of presumption is critical for settlement outcomes and can affect how arbitrage and compliance are assessed.
4.7 Stand-alone storage: power limit + “free contribution” consequence
The amendment adds/clarifies that the energy injected by stand-alone storage in a settlement period cannot exceed what the accepted installed power can deliver; excess energy is treated as produced by the YEKDEM participant designated supplier and counted as free contribution. (LEXPERA)
5) Licensing and structuring: how to select the correct legal pathway
Because Turkey’s storage framework interacts with licensing, the correct pathway depends on your profile:
5.1 Developers adding BESS to a licensed RES/GES project
Typical objective: increase dispatch control, reduce imbalance costs, monetize balancing/ancillary services, and improve revenue profile.
Key legal workstreams
- license amendment / integration into the generation license (as applicable),
- grid connection technical compliance aligned with annexed configurations,
- operational readiness and SCADA/data compliance (see Section 7).
5.2 Suppliers and aggregators building stand-alone storage
The storage regulation’s structure allows stand-alone storage under a supply or aggregator license (with a minimum power condition), and energy injected/withdrawn is considered within settlement for the relevant market participant. (LEXPERA)
Why this is attractive: a portfolio manager can use storage to optimize positions and system balance.
Why it is risky: you are exposed to collateral, settlement volatility, and “establishment within license period” obligations. Notably, market commentary on licensing amendments highlights that guarantees provided to EMRA for independent storage facilities included in supply/aggregator licenses may be forfeited if the facility is not established within the specified period (except force majeure or justified reasons). (Moroğlu Arseven)
5.3 Industrial/commercial users behind-the-meter
If your storage sits at the consumption side, it may be outside licensing, but it is still impacted by grid connection rules, safety permits, and contractual structures (supplier agreements, distribution company rules, building permits, fire safety, insurance).
5.4 License-exempt generation adding storage (newly enabled, but economically constrained)
This can be attractive for self-consumption resilience and peak management, but the amendment’s “no payment for storage-discharged surplus energy” rule means you should treat storage primarily as an optimization/resilience tool rather than a merchant revenue tool. (LEXPERA)
6) Settlement treatment and renewable support interactions: what investors must model correctly
Storage projects fail financially when they are modeled like “ordinary generators.”
6.1 License-exempt + storage: understand the set-off boundary
The post-2025 amendment is explicit: for certain license-exempt plants using set-off, where storage injects into the grid after set-off, there is no payment for that portion (and potentially for all surplus if attribution is impossible), and the energy is counted as a free contribution to YEKDEM. (LEXPERA)
Investor lesson: metering architecture and attribution capability are not “nice to have”; they determine whether any surplus is payable.
6.2 Stand-alone storage: “do not exceed deliverable energy” per accepted power
The amendment introduces a cap logic in settlement periods: injected energy must not exceed what accepted installed power can deliver; excess is treated as free contribution. (LEXPERA)
6.3 Market time granularity is moving
A separate amendment wave discussed in sector news indicates that Turkey plans to apply a 15-minute settlement period in the balancing power market, with infrastructure preparations required until 1 January 2027, and current arrangements continuing until then. (Anadolu Ajansı)
For storage, settlement granularity can change revenue and risk sharply. A shorter settlement interval often increases the value of fast-responding assets but also increases data and compliance sensitivity.
7) Technical-legal compliance: SCADA, data integrity, acceptance tolerance, and “availability”
The storage regime is increasingly “data-centric.” Two examples show the direction:
7.1 SCADA / capacity data tracking documentation
Regulatory change summaries indicate that when a grid operator verifies that capacity data of storage-integrated generation facilities can be transmitted accurately and uninterruptedly to the operator’s SCADA system, a Capacity Data Tracking Certificate is issued. (gaib.org.tr)
If your project’s revenue model depends on market participation (balancing/ancillary), you should treat SCADA integration as a legal deliverable with documentary proof, not only a technical commissioning item.
7.2 Acceptance tolerance and “ready-to-operate”
Regulatory summaries also note a 10% tolerance at acceptance for storage units/facilities. (gaib.org.tr)
Additionally, “ready-to-operate” status is tied to proper operation consistent with annexed connection configurations. (LEXPERA)
Practical implication: a storage facility can be technically present on site yet fail compliance if configuration, data transfer, or acceptance documentation is incomplete.
8) Contracts that make storage projects financeable: what to draft, what to avoid
The legal work in storage projects is not limited to licensing. Bankability depends on the contract stack.
8.1 EPC and supply contracts (BESS is not a typical equipment package)
Storage introduces specialized risks:
- degradation and capacity fade,
- availability and response time guarantees,
- safety and fire risk allocation,
- cyber/security obligations for control systems,
- warranty enforcement across global supply chains.
A financeable BESS contract usually contains:
- measurable performance KPIs (round-trip efficiency, response time, usable capacity),
- testing protocols aligned with grid/operator expectations and settlement assumptions,
- remedies calibrated to revenue impact (liquidated damages for missed milestones, availability penalties),
- spare parts and lifecycle support commitments.
8.2 O&M and asset management
If your storage unit can participate in balancing/ancillary services, your operator’s obligations should include:
- compliance with availability (“ready-to-operate”) requirements,
- accurate data and reporting,
- settlement review and dispute handling,
- event logging and evidence preservation.
8.3 Power offtake and revenue allocation (where storage changes dispatch)
Where a generator sells under a PPA or a structured offtake, you must define:
- who controls charge/discharge decisions,
- who benefits from arbitrage/balancing revenues,
- who bears imbalance costs and settlement corrections,
- how “priority presumptions” (storage injection/withdrawal assumed first) affect billing and revenue splitting. (LEXPERA)
Without explicit drafting, storage becomes a conflict engine between generator, offtaker, and operator.
9) Common disputes and enforcement risks in storage projects (and how to prevent them)
9.1 Non-payment / free-contribution outcomes due to attribution failures
If the amount discharged from storage cannot be identified, the regulation allows no payment for the entire surplus energy in certain license-exempt set-off contexts. (LEXPERA)
This is a “silent killer” because it can appear only after settlement and can trigger lender covenant issues.
Prevention
- metering architecture designed for attribution,
- clear operational protocols (when can discharge occur relative to set-off),
- independent verification at commissioning.
9.2 Guarantee forfeiture for stand-alone storage not built on time
Market commentary on licensing amendments notes that guarantees provided to EMRA for independent storage facilities included in a supply or aggregator license may be forfeited if not established within the period specified (subject to limited exceptions). (Moroğlu Arseven)
Prevention
- realistic construction schedule,
- procurement risk management (battery lead times),
- force majeure documentation discipline.
9.3 SCADA/data compliance disputes
Where SCADA transmission and capacity data certification becomes part of the compliance file, failures can restrict market participation and undermine expected revenues. (gaib.org.tr)
Prevention
- include SCADA acceptance as a condition precedent in EPC contracts,
- require vendor cooperation for grid operator testing.
9.4 Regulatory change risk and settlement redesign
The 2025 package itself demonstrates that settlement logic can be updated and annexes can be expanded. (LEXPERA)
Projects should include change-in-law mechanisms in private contracts (EPC, O&M, offtake) so that regulatory evolution does not automatically become a private-law default event.
10) A practical roadmap for storage-integrated generation projects (client-ready)
Phase 1 — Feasibility and structuring
- Choose model: integrated vs stand-alone vs behind-the-meter vs license-exempt + storage.
- Confirm which settlement limitations apply (especially no-payment/free-contribution rules). (LEXPERA)
- Build a metering and attribution concept from day one.
Phase 2 — Licensing / regulatory filings
- For integrated projects: align license amendment needs and grid operator expectations.
- For stand-alone: confirm license category (supply/aggregator) and minimum power condition. (LEXPERA)
- Plan guarantee and establishment timeline (avoid forfeiture risk). (Moroğlu Arseven)
Phase 3 — Grid connection and technical compliance
- Follow annexed connection configurations and ensure documentation consistency. (LEXPERA)
- Implement SCADA/data transmission requirements and secure proof/certification where applicable. (gaib.org.tr)
Phase 4 — Contracts and bankability
- EPC + supply contracts with performance and safety guarantees.
- O&M with compliance and settlement governance.
- Offtake/PPA clauses allocating dispatch control, imbalance, and storage value.
Phase 5 — Commissioning and operations
- Acceptance tests reflecting both technical and settlement assumptions (including the “ready-to-operate” definition). (LEXPERA)
- Settlement monitoring, dispute processes, and evidence retention.
- If market participation is planned: prepare for the evolving balancing/settlement timeframe. (Anadolu Ajansı)
Conclusion: storage projects win on compliance design, not only technology
Turkey’s storage regime has moved from “permission to build” to “rules-based integration into settlement and system services.” The 29 December 2025 amendments (effective 1 January 2026) materially changed what is possible—especially by enabling storage for certain license-exempt plants while also imposing strict non-payment and free-contribution outcomes for storage-discharged surplus energy in set-off contexts. (LEXPERA)
For developers and investors, the bankable approach is clear:
- select the correct legal model (integrated vs stand-alone vs behind-the-meter vs license-exempt + storage),
- build metering/data attribution into the technical design,
- align SCADA and configuration compliance with annex requirements,
- draft contracts that allocate storage value and regulatory risk realistically,
- treat settlement evolution as a core investment risk factor.
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