Information Note on the Türkiye Green Taxonomy Regulation

The Türkiye Green Taxonomy Regulation (the ‘Regulation’) was published in the Official Gazette dated 24 September 2026 and numbered 33380, and entered into force on the same date. The Regulation sets out the procedures and principles for implementing the Türkiye Green Taxonomy with a view to classifying sustainable economic activities, encouraging the flow of finance towards sustainable investments, and preventing greenwashing.

The key provisions of the Regulation relevant to the maritime sector are summarized below:

• Maritime Activities: Under Annex 1 to the Regulation, the transport activities relating to climate change mitigation expressly include:

1. ‘Sea and coastal freight water transport, vessels for port operations and auxiliary activities’ (6.10);
2. ‘Sea and coastal passenger water transport’ (6.11); and
3. ‘Retrofitting of sea and coastal freight and passenger water transport’ (6.12).

These activities are categorized as ‘transitional activities’ under the Regulation.

Under the Regulation, a transitional activity is an activity in a sector or industry for which low-carbon economic and technological alternatives are not yet available, which has the lowest greenhouse gas emission levels and does not hamper the development and deployment of low-carbon alternatives.

Annex 1 also designates ‘Inland passenger water transport’, ‘Inland freight water transport’, and ‘Retrofitting of inland water passenger and freight transport’ as transitional activities.

• Climate Change Adaptation: Activities relating to the maritime sector appear in Annex 1 not only under climate change mitigation, but also under the objective of climate change adaptation. In this context, sea and coastal freight water transport, vessels used for port operations and auxiliary activities, sea and coastal passenger water transport, and the retrofitting of sea and coastal freight and passenger water transport are listed among the activities relating to climate change adaptation.
• Taxonomy-Alignment Conditions: An activity’s inclusion in Annex 1 does not, by itself, mean that it is environmentally sustainable or Taxonomy-aligned. For an economic activity to be regarded as Taxonomy-aligned, it must:

1. contribute substantially to at least one of the objectives of climate change mitigation, climate change adaptation, the sustainable use and protection of water and marine resources, the transition to a circular economy, pollution prevention and control, or the protection and restoration of biodiversity and ecosystems;
2. do no significant harm to any of the other environmental objectives; and
3. comply with the minimum social safeguards.

All of these conditions must be satisfied.

Whether activities satisfy these conditions will be assessed against technical screening criteria to be determined by the Directorate of Climate Change (the ‘Directorate’). When determining the technical screening criteria, the environmental impacts of the economic activity, and of the products or services provided through that activity, will be considered throughout their life cycles. The criteria will be published on the Directorate’s website; updates to the criteria will be published by 15 December each year and applied from the following year.

Where an economic activity listed in Annex 1 satisfies the above conditions and thereby becomes a ‘Taxonomy-aligned economic activity’, this does not, in itself, give rise to a mandatory reporting obligation for the undertaking concerned. Article 13 of the Regulation provides that institutions, organizations, and undertakings within the scope of Annex 1 may report, while mandatory reporting is separately prescribed for the financial institutions listed in that article. However, under Article 23 of the Regulation, administrative fines may be imposed pursuant to Climate Law No. 7552 where those reporting under Article 13 fail to fulfil their obligations to submit the notifications, information, and documents required for reporting. Accordingly, although the commencement of reporting is voluntary for undertakings within the scope of Annex 1, once an undertaking reports, it must comply with the notification, information, and document-submission obligations laid down in the Regulation.

• Protection of Water and Marine Resources: The Regulation separately identifies the sustainable use and protection of water and marine resources as an environmental objective. This objective encompasses improving the condition of, contributing to the protection of, and preventing pollution of surface water and groundwater resources, including coastal and transitional waters, as well as marine waters.

Accordingly, maritime activities will be assessed not only in terms of climate change mitigation, but also in terms of their impact on water and marine resources under the requirement to do no significant harm to the other environmental objectives.

• Reporting: Institutions, organizations, and undertakings carrying out at least one Taxonomy-eligible economic activity listed in Annex 1 may prepare Taxonomy reports in accordance with the reporting templates to be published on the Directorate’s website. The Regulation therefore does not currently impose a direct mandatory Taxonomy reporting obligation on maritime undertakings within the scope of Annex 1.

Reporting will be based on turnover from Taxonomy-eligible or Taxonomy-aligned products and services, and the related capital expenditure and operating expenditure. Where the ratio of turnover derived from activities within Annex 1 to total turnover, capital expenditure to total capital expenditure, or operating expenditure to total operating expenditure is below 10%, the relevant key performance indicator may be omitted from the report.

Reports will cover the preceding year’s reporting period and must be uploaded to the Online Taxonomy Management System by the end of the sixth month following the end of the relevant financial statement period or special accounting period. As a rule, Taxonomy reports uploaded to the system will be publicly available.

• Reporting Obligations of Financial Institutions: Mandatory Taxonomy reporting is prescribed for banks, brokerage firms, investment trusts, portfolio management companies, and insurance, reinsurance, and pension companies. However, these financial institutions are not required to make Taxonomy reports until 1 January 2029.

Financial institutions may request institutions, organizations, and undertakings within the scope of Annex 1 to report under the Regulation in relation to business and transactions that may be included in the financial institutions’ own reporting.

Accordingly, although reporting is not directly mandatory for maritime undertakings, Taxonomy reporting is expected to gain practical significance, particularly in connection with ship and fleet finance, investments in new vessels, fleet renewal or retrofitting investments, and insurance arrangements.

• Greenwashing: The Regulation defines ‘greenwashing’ as the deceptive use of public relations, financing, advertising, or marketing methods to create the impression that an institution’s, organization’s, or undertaking’s products or services contribute substantially to one or more environmental objectives, do no significant harm to the other environmental objectives, and comply with the minimum social safeguards.

Under this provision, environmental claims such as ‘green’, ‘low-carbon’, ‘environmentally friendly’, and ‘sustainable’ in relation to maritime transport services, vessels, or fleet investments should have a concrete and verifiable basis.

• Taxonomy Transition Plan and Verification: The Regulation defines a ‘Taxonomy transition plan’ as a strategic plan prepared by institutions, organizations, and undertakings to comply with the technical screening criteria or to manage risks arising from the transition to a low-emission economy. The Directorate will separately determine the procedures and principles for preparing Taxonomy transition plans and verifying Taxonomy reports.
• Administrative Sanctions: Under Article 23 of the Regulation, reporting entities under Article 13 that fail to fulfil their obligation to provide the notifications, information, and documents required for reporting will be subject to administrative fines in accordance with paragraphs 6, 9, and 11 of Article 14 of Climate Law No. 7552.

Accordingly:

1. Under Article 14(6) of the Law, any person who fails to fulfil the obligation to provide information, documents, and data prescribed by the Law will be subject to an administrative fine of TRY 213,333 throughout 2026. This amount is updated annually by the revaluation rate;
2. Under paragraph 9, where an act requiring an administrative fine under the Law is repeated within three years from the date on which the relevant person is notified of the fine, the fine will be increased by 100% for the first repetition and by 200% for the second and subsequent repetitions; and
3. Under paragraph 11, the administrative fine imposed for each act under the Law may not exceed the upper limit of TRY 62,745,000 applicable for 2026.

In conclusion, Annex 1 to the Regulation expressly brings sea and coastal freight water transport, vessels used for port operations and auxiliary activities, sea and coastal passenger water transport, and the retrofitting of freight and passenger water transport within the scope of the Türkiye Green Taxonomy. The separate categorization of these activities as ‘transitional activities’ for climate change mitigation shows that the Regulation specifically addresses the maritime sector in the transition to a low-emission economy.

Although the Regulation does not currently impose direct mandatory Taxonomy reporting on maritime undertakings, financial institutions may request Taxonomy reports from undertakings in relation to transactions covered by the financial institutions’ own reporting. The Regulation is therefore expected to gain practical significance, particularly in ship and fleet finance, fleet renewal and retrofitting investments, and insurance processes.

It is therefore important to monitor the technical screening criteria and reporting templates that the Directorate will publish, particularly for maritime activities under items 6.10, 6.11, and 6.12; assess existing and planned ship and fleet investments against those criteria; and review environmental claims concerning maritime services and investments in light of the greenwashing provisions.

The Regulation and Annex 1 are available at the links below:

• Regulation: https://www.resmigazete.gov.tr/eskiler/2026/09/20260924-1.htm
• Annex 1: https://www.resmigazete.gov.tr/eskiler/2026/09/20260924-1-1.pdf

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