The Law No. 7554 was enacted on July 24, 2025, to foster a more efficient regulatory environment for green energy projects and mining investments. The so-called “super permit” regime introduced by the new law aims to simplify the permitting and licensing procedures for renewable energy and mining sectors, ensure a secure supply of industrial raw materials and electricity, reduce dependency on foreign mineral resources, and clarify rehabilitation obligations to support environmentally friendly mining practices.

The main changes introduced by Law No. 7554 in relation to the energy sector are as follows:

• Under the Renewable Energy Law, the Ministry of Energy and Natural Resources (“MENR”) is now authorized to approve zoning plans, construction permits, and occupancy permits for licensed wind and solar power plants. This enables investors to manage these approvals directly via MENR, expediting bureaucratic procedures and facilitating access to public services.

• A newly introduced provisional article of the Electricity Market Law grants the Energy Market Regulatory Authority (“EMRA”) the power to carry out urgent expropriations for renewable energy investments until 2030. The President of the Republic may extend this authority once for an additional five years.

• Through an amendment to article 14 of the Pasture Law , allocation changes in pasture lands for Renewable Energy Resource Area (YEKA) projects can be made by the governorships. In pastures, summer grazing lands (yaylak), and winter grazing lands (kışlak) that are in very good or good condition and classification, the allocation purpose may also be changed for the purpose of renewable energy production.

• Amendments to the Renewable Energy Law aims to enhance clarity in the forest permit process required for wind and solar power plants. The law stipulates that such applications must be finalized within 60 days. To further streamline the process, the requirement for ornithological studies is abolished, except for wind projects located on main bird migration routes, and for solar projects located at bottlenecks on main bird migration routes.

• A temporary article added to the Electricity Market Law provides a provisional compliance opportunity for licensed power plants operating without a building and/or occupancy permit. Licensed electricity generation facilities and their mandatory infrastructure, commissioned before December 31, 2024 without a building or occupancy permit, may be granted a Generation Facility Conformity Certificate if included in zoning plans, applied for within one year, and supported by a structural safety report and technical responsibility declaration. This certificate replaces the workplace opening and operation license. A fee equal to 0.1% of the investment amount is collected as a Generation Facility Conformity Certificate fee. Administrative sanctions, demolition orders, and fines issued before this provision’s effective date will not be enforced. Related lawsuits or objections will be dismissed, the costs of the proceedings will be left on the parties and no attorney’s fee shall be awarded

• Previously, electricity facilities using Group IV(b) minerals, comprising mainly indigenous coals, as an input and commissioned by December 31, 2020, benefited from an 85% reduction in permit, rent, easement, and usage fees for 10 years. The new provision extends the commissioning deadline to December 31, 2030 and increases the incentive period to 15 years, while maintaining the same scope and reduction rate.

• Following the amendment to the Environmental Law , the “Environmental Impact Assessment (“EIA”) Not Required” practice has been abolished. This amendment was introduced on the grounds that the phrase “EIA Not Required” caused confusion and led to the mistaken belief that such projects were exempt from environmental obligations. In practice, however, these projects are still subject to an assessment process, and that such companies still bear environmental obligations. Thus, this amendment aims to eliminate confusion and emphasize that each project still must comply with environmental obligations. Additionally, the EIA process may now proceed concurrently with other administrative permits, helping to prevent delays in investment timelines.

Law No. 7554 also introduced the following changes in relation to the mining sector:

• Amendment to article 7 of the Mining Law aims to simplify permitting procedures and accelerate investment processes. The updated procedure is outlined below:

o Investments planned in sensitive areas — such as protected zones, forests, tourism sites, and military regions — will be reported to the General Directorate of Mining and Petroleum Affairs (“MAPEG”) by the relevant public authorities. Before a mining license is granted in the areas notified except for forests, MAPEG is required to obtain opinions from competent institutions. If no response is received within three months, the relevant institution shall be given an additional period of one month by MAPEG.
o In state forests, the exploration and operation of mines, as well as the construction of essential facilities such as roads, energy, water, communication, and other infrastructure required for mining activities, shall be permitted in three months and free of charge for a period of 24 months, upon the request of MAPEG. This permit may be extended for additional 12 months. A corresponding undertaking letter regarding the free permit must be submitted to the General Directorate of Forestry. However, if the permit is operated, transferred, or assigned to third parties (natural or legal persons), the required fees must be paid into the special budget account of the General Directorate of Forestry, and a paid undertaking letter must be submitted within one month. Permits granted prior to the entry into force of this provision shall remain valid for the duration of the license and must be transferred to MAPEG within six months.
o After the license is issued, mining activities continue even if the area becomes subject to a permit. If a cultural asset is discovered within a license area, mining operations may proceed only with the approval of the Ministry of Culture and Tourism. Otherwise, the investor will be compensated from the administration budget for incurred investment costs.
o The relevant institutions must provide their input/opinion for the EIA process, carried out by Environment, Urbanization and Climate Change, within three months. If the institutions request additional time, an additional period of maximum one month will be granted. If a relevant entity fails to respond within this period, its opinion will be deemed affirmative.
o In cases where Group IV and strategic or critical mines are not permitted by relevant institutions, MENR will issue the final decision, taking into account the resource potential, location, and overall economic value.

• With an amendment to the Article 8 of the Mining Law “strategic or critical minerals” are defined and the following regulations are introduced regarding these minerals:

o Strategic or critical minerals will be identified by MENR based on the opinions of relevant ministries and public institutions.
o Mining activities related to such minerals may be subject to urgent expropriation.
o Additionally, the President of the Republic may decide that license holders must stockpile a certain amount or percentage of strategic or critical minerals, provided that it does not exceed 10% of the previous year’s production.

• It is now mandatory for license holders to pay a rehabilitation fee equivalent to the operating license fee. Additionally, the previous minimum state royalty fee – which was at least equal to the operating license fee – is also increased by 50% of the license fee.

• With an amendment to the Mining Law, if mining activities conducted to meet the country’s electricity needs overlap with areas registered as olive groves or containing olive trees within the map and coordinate list annexed to the Mining Law, and if relocation is not feasible, MENR may authorize the relocation of olive trees, construction of temporary facilities, and continuation of mining operations in the public interest. All costs and responsibilities related to the relocation of olive trees shall be borne by the party authorized to carry out the mining activity. Additionally, authorized companies have to create oil groves which consist of at least twice as many olive trees as the number of relocated and non-relocated olive trees. For each year that mining activities are carried out in areas registered as olive groves or in areas where there are actually olive groves, the license holder is separately charged the amount of the operating license fee to ensure the rehabilitation works of these areas. These areas shall also be rehabilitated by planting the same number of olive trees as the number of olive trees in the area before the mining activities.

This information is provided for your convenience and does not constitute legal advice. It is prepared for the general information of our clients and other interested persons. This should not be acted upon in any specific situation without appropriate legal advice. This information is protected by copyright and may not be reproduced or translated without the prior written permission of Ergün Avukatlık Bürosu.