Recent Developments
With the amendments published in the Official Gazette dated 29 December 2025 and numbered 33122, comprehensive amendments to storage activities in the electricity market have been made to (i) the Regulation on Storage Activities in the Electricity Market (“Storage Regulation”), (ii) the Electricity Market Balancing and Settlement Regulation (“Balancing Regulation”), (iii) the Electricity Market Licensing Regulation (“License Regulation”) and (iv) the Regulation on the Certification and Support of Renewable Energy Resources (“YEKDEM Regulation”) (collectively, “Amendments”). You may access the text of the Amendments here.
What do the Amendments introduce?
In summary, the Amendments introduce the following key innovations:
1. Amendments to the Storage Regulation
a. Electricity storage facilities established by license-exempt electricity generation facilities
i. Pursuant to the Amendments, electricity storage facilities established by license-exempt electricity generation facilities have been included among the facilities through which activities may be carried out through an electricity storage unit or facility. Accordingly, electricity storage facilities may be established at license-exempt electricity generation facilities that have received an invitation letter within the framework of the Regulation on License-Exempt Electricity Generation in the Electricity Market (“License-Exempt Electricity Generation Regulation”) and are subject to monthly netting for surplus energy pursuant to Article 26 of the License-Exempt Electricity Generation Regulation.
ii. Where energy is injected into the grid from electricity storage facilities established by license-exempt electricity generation facilities, no payment will be made for the portion of the surplus energy remaining after netting that is injected from the storage. If the amount injected from the storage cannot be determined, no payment will be made for the entire amount of the surplus energy. The relevant energy will be deemed to have been generated by the designated supply company as a participant in the Renewable Energy Resources Support Scheme (YEKDEM) and will be treated as a free-of-charge contribution to YEKDEM.
b. Electricity storage units integrated into generation facilities
i. Prior to the Amendments, the amount of energy to be injected into the system, on a settlement period basis, by electricity generation facilities with storage and by generation facilities incorporating an integrated electricity storage unit could not exceed the amount of generation that could be carried out based on the total electrical installed capacity of the units whose provisional acceptance had been completed for the main source. However, the Amendments regulate that, for generation facilities whose main source recorded in the generation license has been partially commissioned or not commissioned at all, energy may be injected into the grid up to the accepted portion of the storage unit or storage facility, if this does not exceed the electrical installed capacity of the main source recorded in the generation license, and subject to the system operator (i.e., Türkiye Elektrik İletim Anonim Şirketi (TEİAŞ)) finding it appropriate in terms of technical requirements and compliance with the conditions determined within this scope.
ii. Prior to the Amendments, electricity storage units integrated into generation facilities could participate in ancillary services, if they met the relevant legislative requirements, and in the balancing power market, if they qualified as a balancing unit. The Amendments explicitly regulate that these electricity storage units may participate in these services and markets through the settlement-based feed-in and feed-out units (UEVÇB) of the generation facility with which they are associated.
iii. With the Amendments, for electricity generation facilities with storage and for generation facilities with an electricity storage unit integrated into the generation facility in any settlement period: (a) if energy is withdrawn from the grid and if there is a withdrawal by the storage facility in the relevant settlement period, the energy withdrawn from the grid will be deemed to have been primarily withdrawn by the storage facility; and (b) if that energy is injected into the grid and if there is an injection by the storage facility in the relevant settlement period, the energy injected into the grid will be deemed to have been primarily injected by the storage facility.
c. Electricity storage facilities integrated into consumption facilities
i. Prior to the Amendments, electricity storage facilities established within the boundaries of an organized industrial zone (OIZ) by the OIZ legal entity were deemed to be electricity storage facilities integrated into a consumption facility. With the Amendments, a similar provision is envisaged for the industrial zones too. Accordingly, electricity storage facilities established within the boundaries of an industrial zone by the industrial zone legal entity will now also be deemed to be electricity storage facilities integrated into a consumption facility.
d. Stand-alone electricity storage facilities
i. With the Amendments, the amount of energy to be injected into the system by stand-alone electricity storage facilities, on a settlement period basis, may not exceed the amount of energy that can be injected based on the electrical installed capacity of the storage facility whose acceptance has been completed. If the amount of energy that can be injected based on the installed capacity is exceeded, the excess energy will be deemed to have been generated by the designated supply company as a YEKDEM participant and will be treated as a free-of-charge contribution to YEKDEM.
2. Amendments to the Balancing Regulation
i. Prior to the Amendments, electricity storage units established within electricity generation facilities with storage and electricity storage units integrated into generation facilities were associated with the relevant UEVÇBs of the generation facility. With the Amendments, under the connection configurations set out in the annexes to the Storage Regulation, if a generation facility has more than one UEVÇB, the relevant UEVÇBs will be associated with each other.
ii. With the Amendments, if electricity storage units established within electricity generation facilities with storage are installed in line with the connection configurations set out in Annex 1 of the Storage Regulation, all measurement points at the same voltage level located at the grid exit point will be registered under one UEVÇB, and all measurement points connected to the electricity storage units associated with this UEVÇB will be registered under a different UEVÇB. In electricity generation facilities established within the scope of the 11th paragraph of Article 7 of Electricity Market Law No. 6446 (“Law”), the above regulations regarding UEVÇBs will be applied only to the unit or units established in connection with the same capacity increase within the framework of the 11th paragraph of Article 7 of the Law.
iii. With the Amendments, the facilities and units subject to the obligation to qualify as a balancing unit pursuant to the second paragraph of Article 22 of the Storage Regulation have been amended, as follows:
- The “stand-alone electricity storage units or facilities that are requested by the market participant in whose name they are registered, that have an operational electrical installed capacity of at least 10 megawatts and above, and whose participation is found appropriate by the system operator”, which were accepted as balancing units prior to the Amendments, have been re-regulated as “stand-alone electricity storage units or facilities whose operational electrical installed capacity is 30 megawatts and above”.
- With the Amendments, a new balancing unit has been added to the same paragraph: “the UEVÇBs with which the UEVÇBs created for electricity storage units within electricity generation facilities with storage and storage integrated electricity generation facilities having, within their structure, a storage unit whose operational electrical installed capacity is 30 megawatts and above, are associated.”
iv. With the Amendments, the generation facilities that are exempt from the obligation to qualify as a balancing unit pursuant to the fourth paragraph of Article 22 of the Storage Regulation, but that may qualify as a balancing unit if requested by the relevant market participant and found appropriate by the system operator, have been amended, as follows:
- Prior to the Amendments, the “UEVÇBs with which the UEVÇBs created for electricity storage units within electricity generation facilities with storage and for electricity storage units integrated into generation facilities are associated” listed under the relevant paragraph were re-regulated as “the UEVÇBs with which the UEVÇBs created for storage integrated electricity generation facilities having, within their structure, a storage unit whose operational electrical installed capacity is below 30 megawatts and electricity storage units within electricity generation facilities with storage, are associated”.
- With the Amendments, a new balancing unit has been added to the same paragraph: “stand-alone electricity storage units or facilities with an operational electrical installed capacity below 30 megawatts.”
3. Amendments to the License Regulation
i. Prior to the Amendments, the scope of the second paragraph of Article 15 of the License Regulation, which applied where an application to amend a preliminary license/license was filed by changing the mechanical capacity or the electrical installed capacity of the generation facility subject to the preliminary license/license, has been expanded to also include changes in the installed capacity or capacity of storage units in electricity generation facilities with storage; accordingly, in these cases as well, opinions must be requested from TEİAŞ or the legal entity holding the distribution license in the distribution region where the generation facility is located regarding the connection to and use of the transmission or distribution system.
ii. With the Amendments, whereas the subject matter of preliminary license amendment applications within the scope of the 13th paragraph of Article 18 of the License Regulation was “the addition of an electricity storage unit integrated into the generation facility subject to the preliminary license,” the provision has been expanded to read “the addition of an electricity storage unit integrated into the generation facility subject to the preliminary license or the modification of the installed capacity or capacity of existing integrated storage units.”
iii. With the Amendments, whereas the subject matter of license amendment applications within the scope of the 18th paragraph of Article 24 of the License Regulation was “the addition of an electricity storage unit to the facility subject to the generation license,” the provision has been expanded to read “the addition of an electricity storage unit integrated into the facility subject to the generation license or the modification of the installed capacity or capacity of existing integrated storage units.”
iv. With the Amendments, the amount of energy to be injected into the system by stand-alone electricity storage facilities established under supply and aggregation licenses may not exceed the amount of energy that can be injected into the system based on the electrical installed capacity of the facility whose acceptance has been completed. If excess energy is injected into the system, transactions will be carried out regarding this energy within the scope of Article 12 of the YEKDEM Regulation.
v. With the Amendments, electricity generation facilities with storage and generation facilities incorporating an integrated electricity storage unit may inject into the system, on a settlement period basis, an amount of energy equal to the amount of generation that can be produced based on the total electrical installed capacity of the units whose acceptance based on the main source has been completed, without prejudice to the provision of the seventh paragraph of Article 5 of the Storage Regulation. In addition, if electricity generation facilities with storage and generation facilities incorporating an integrated electricity storage unit draw energy from the system, the amounts of energy drawn from the system and stored will not be included in the purchase account within the scope of subparagraph (ç) of the first paragraph of Article 30 of the License Regulation.
4. Amendments to the YEKDEM Regulation
i. With the Amendments, (i) the settlement-based injection amount (UEVM) of the YEKDEM participant’s UEVÇB within the scope of YEKDEM for the relevant settlement period (UEVMi,b,t,u) and (ii) the YEK price (YEKFi,b,u) to be applied to the YEKDEM participant for the generation facility to which this UEVÇB is connected, each of which is used in the calculation of the Total Renewable Energy Resources (YEK) Amount (YEKTOB), have been revised to be determined by taking into account whether the energy was injected into the system without storage or after having been stored in the relevant settlement period. In this context, the definition of YEKTOB has also been aligned by adding the phrase “the amount of energy injected into the system without storage or after storage.”
ii. With the Amendments, regarding the UEVM of (i) the electricity storage unit established within an electricity generation facility with storage and (ii) the electricity storage unit integrated into a generation facility within the scope of YEKDEM, if energy is withdrawn from the grid by these units in any settlement period, it will be deemed that an amount of energy equal to the amount withdrawn from the grid is primarily injected from the electricity storage unit without being subject to YEKDEM. Furthermore, if electricity storage units integrated into generation facilities are installed in line with the configuration set out in Annex 2 of the Storage Regulation and constitute an integrated auxiliary resource together with the storage unit, the energy generated from the auxiliary resource and injected into the grid will be deemed not to be within the scope of YEKDEM.
iii. With the Amendments, by adding the phrases “whose acceptance has been completed” and “if insufficient, of the storage unit” to the eighth paragraph of Article 8 of the YEKDEM Regulation, the paragraph now reads as follows: “In electricity generation facilities with storage and in electricity generation facilities where there is an electricity storage unit integrated into a generation facility within the scope of YEKDEM, if energy in excess of the energy that can be generated based on the electrical installed capacity of the generation facility whose acceptance has been completed is injected into the grid, this energy must first be deducted from the UEVM of the relevant generation facility and, if insufficient, from that of the storage unit.” Furthermore, it has been regulated that, in electricity generation facilities with an electrical capacity increase, in determining the injection amount to be used in the calculations within the scope of the YEKDEM Regulation, the operational power values and ratios will be considered depending on the relevance of the main source and the capacity increases.
iv. With the Amendments, if electricity generation facilities with storage and generation facilities having an electricity storage unit integrated into the generation facility exit the scope of YEKDEM, and if energy that was generated and stored while they were within the scope of YEKDEM is injected into the grid, this energy will not be considered in the YEK UEVM calculation.
v. With the Amendments, for electricity generated in wind- or solar energy-based electricity generation facilities with storage that entered into operation after 1 May 2023 and injected into the system after being stored in the electricity storage unit, the prices determined for “electricity storage facilities integrated into wind or solar energy-based generation facilities” set out in the table included in Annex 1 to Presidential Decree No. 7189 (“Decree No. 7189”), which announces the YEKDEM implementation prices and periods, will be applied. If the energy is injected into the system without being stored, the prices determined pursuant to Decree No. 7189 for wind energy-based generation facilities or solar energy-based generation facilities, as applicable, depending on the resource type, will be applied. However, this regulation will not apply to integrated storage units located within generation facilities.
vi. With the Amendments, in electricity generation facilities with storage, for the YEK UEVM calculations of separately registered UEVÇBs, the operational power of the relevant UEVÇB and the operational power information within the scope of YEKDEM will be used.
vii. With the Amendments, UEVMs exceeding the maximum amount of generation that can be carried out in a settlement period based on the electrical installed capacity recorded in generation, supply and aggregation licenses and whose acceptance has been completed and that has been put into operation, will not be considered in the relevant participant’s settlement calculations, without prejudice to the provision of the seventh paragraph of Article 5 of the Storage Regulation. Energy withdrawn from the grid, stored in the electricity storage unit and then injected back into the system will also be evaluated within this scope. The relevant energy will be deemed to have been generated by the designated supply company as a YEKDEM participant and will be treated as a free-of-charge contribution to YEKDEM.
Conclusion
As a result, the Amendments have updated the rules regarding storage activities in the electricity market, thereby providing a clearer and more comprehensive framework for implementation.
