Licensing Process for Energy Companies in Türkiye (Electricity – Natural Gas – Oil – LPG)

 This guide covers the licensing/pre-licensing process, required permits, electronic application system, deadlines, obligations, and risks for companies wishing to operate in the energy sector in Türkiye. It includes a legal guide for the electricity, natural gas, oil, LPG, and charging services markets. How does the licensing process for energy companies work in Türkiye?

1) Why is licensing mandatory and why is it so critical?

Energy markets public interests . Therefore, in Turkey, "freedom of activity" in the energy sector is not the general rule; licensing (and preliminary licensing for some production projects) is mandatory depending on the type of activity.

Licensing is not just a "permission certificate". It also means the company:

• financial sufficiency,

• partnership structure and control changes,

• technical/operational preparation,

• reporting and audit compliance capacity

This places it under "regulatory oversight" from the outset. The main executor of this oversight Energy Market Regulatory Authority (EPDK).

2) Core players and authority map

Although EPDK (Energy Market Regulatory Authority) is central to the licensing process, in practice, it proceeds simultaneously with the following institutions:

• Ministry of Energy and Natural Resources: policy/strategy, certain specific areas and coordination (particularly renewable policies and certain application mechanisms).

• Turkish Electricity Transmission Corporation (TEİAŞ): transmission link, capacity and system utilization dimension (particularly critical in generation projects).

• Energy Markets Operating CompanyInc.:marketoperation activities and certain market processes (according to your operating model).

• Petroleum Pipeline Transportation Inc.:practically significant in terms of natural gas transmission/contracts (especially in wholesale/import arrangements).

• Social Security Institution and Revenue Administration: In some markets, "overdue debt" checks can be decisive in the application/extension stages.
  

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3) The question of "Which license?": Establishing the right business model

The most common mistake made by energy companies is failing to determine the license type "according to the definition of market activity in the legislation, rather than according to the business idea." The first step is to clarify this question:

What specific market activity will your company be engaged in?

 Electricity generation, supply, or distribution? Natural gas wholesale or storage? Petroleum distribution or LPG autogas dealership? Charging network operation?

This is because many markets a separate licensing logic for each activity and sometimes for each facility (especially in the oil/LPG sector, a facility-focused licensing approach is common).

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4) Licensing in electricity companies: Associate degree → Bachelor's degree

4.1 The “Associate Degree” Logic in Production Projects

In electricity generation (especially in new power plant investments), in most scenarios, the company first a preliminary license ; this preliminary license provides "time and framework" for gathering the necessary permits/licenses/approvals for the investment to be implemented.

the Electricity Market Law No. 6446; a legal entity applying for a production license a preliminary license for a fixed period ; the preliminary license period generally cannot exceed 24 months (there are extension mechanisms depending on the resource/installed capacity) and if the preliminary license obligations are not fulfilled, a license will not be granted; furthermore, restrictions and sanctions are foreseen regarding changes in the ownership structure until the license is obtained.

4.2 Licensing for non-production activities (supply, etc.)

In models such as supply/retail sales, the process often proceeds directly with a license application without the need for a "pre-licensing" stage. However, this does not mean it is easier: the quality of the filing becomes critical due to financial adequacy, organizational structure, guarantees, market participation requirements, and consumer obligations.

4.3 Network connection and system usage aspect (the heart of the project)

Especially in production, the “legal core” of licensing is often connection capacity and connection agreements. Procedures and principles regarding connection to and use of the electricity transmission/distribution system are also regulated separately; this framework determines the technical conditions under which the facility can be connected to the system.

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5) How to apply to EPDK? (Electronic application system)

Today, a significant portion of licensing processes are conducted through electronic application infrastructure . The "procedures and principles" regarding the electronic or written submission of preliminary/license applications, amendments/terminations/facility transfers/mergers-divisions, and similar processes in the electricity market have been systematized by a Board decision. This text outlines these principles:

• The "authorized party to contact" concept,

• system access,

• Login and signing via e-government/e-signature,

• submission of the information and documents listed in the appendices

It includes provisions that are critical in practice, such as those mentioned above.

Furthermore, the EPDK's application system clearly states the login options using e-Government, mobile signature, or electronic signature.

Practical note: File rejection is often not due to "substantive" reasons, authorization, signature, UETS/communication, attachment format, or incomplete uploading . Therefore, it is essential to clearly establish the "authorized contact person" definition and internal signature circular/representation-binding chain before submitting the application.

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6) Licensing in the natural gas market: Types and duration logic

The types of licenses in the natural gas market are clearly defined in the legislation. The Natural Gas Market Licensing Regulationimport, transmission, storage, wholesale, distribution, CNG, export, and liquefaction licenses (the liquefaction license became separately visible with the 2025 amendment).

On the other hand, Article 4646 of the Natural Gas Market Law stipulates that license applications must be answered within a maximum of 60 days ; the reason for rejection must be stated

Strategic comment: The 60-day response time makes it even more important in practice to submit the application "complete and accurate." Because requests for additional information from the institution can effectively prolong the application process.

Therefore, before applying for natural gas:

• sourcing/supply contract structure,

• infrastructure access,

• storage/transmission capacity,

organizational and financial plan

These elements need to be presented within a reasonable framework.

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7) Oil market licenses: Strict facility and operation-focused oversight

In the oil market, a license is defined as a permit required to operate in the market, and in most scenarios, the operation + facility axis.

In this field, the focus is generally more on "operational adaptation":

• storage/transmission facility security,
• automation/monitoring infrastructures,
• registration and notification obligations,
• Issues such as establishing dealership/distributor relationships in accordance with regulations are crucial for the sustainability of the license
  

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8) LPG market licenses: The distributor-storage-autogas dealership triangle

In the LPG sector, licensing types and market structure are governed by a separate set of laws and regulations. The most common licenses encountered in practice are:

• LPG distributor,

• LPG storage,

• LPG auto gas dealership

It rotates around its axis.

An important point of compliance is this: In LPG license applications (especially in procedures such as license extensions), overdue social security premium/administrative fine debts and overdue debts under Law No. 6183 is required; the institution obtains this information from the relevant administrations.

Therefore, in the LPG sector, a license is not just a document that is "obtained," but also ensures continued financial and administrative compliance .

 

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9) Electric vehicle charging service: Charging network operator license

One of the fastest-growing areas in the energy transition is charging services. The framework for this area the Charging Services Regulation , which sets out the procedures and principles for the establishment of charging units/stations, the operation of charging networks, and the provision of services.

In its announcement regarding the "Charging Network Operator License," EPDK also stated:

• the relevant regulation and application procedures and principles have entered into force upon publication in the Official Gazette,

• License applications have been accepted through the electronic application system since a certain date

• Applications submitted in person or by mail will not be considered

He has stated it clearly.

Practical note: While a charging network license is an "energy market license," it often requires further consideration on-site, municipal permits and local authorizations such as zoning/fire/business licence permits (especially in the case of standalone station configurations).

10) How to prepare the license file? Step-by-step checklist

The following structure operates as the “general logic” in most energy markets:

A) Preliminary preparation (before application)

1. Activity and license type selection: Can more than one license be required? (Number of activities/facilities, market role)

2. Company structure: Ownership structure, control relationships, chain of representation, capital plan.

3. Project/operation model: Sourcing, supply chain, site/facility design, financing plan.

4. Permit inventory: EIA, zoning, construction permits, ownership/usage rights, connection processes, etc.

B) Application (electronic/written process)

• Definition of contact person

• Electronic signature/mobile signature and system uploads

• The information and documents listed in the appendices must be presented in the correct format

• C) Evaluation and Board Decision

  • Administrative review (missing/formatted)

  • Technical and financial adequacy review

  • Additional information/documents may be requested if necessary

  D) Postgraduate adaptation (the main “risk area”)

  • Notification/reporting obligations

  • Regulatory approval processes in transactions such as facility transfers, mergers and divisions, and share transfers

  • Audits and sanctions (fines, suspension, cancellation risks in case of non-compliance)

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  11) Common mistakes and legal risks

  1. Incorrect license selection: Failing to match the activity with the "regulatory definition" instead of the "commercial definition".

  2. Not prioritizing site/connection realities over licensing: Projects can stall, especially in production, if connection capacity and site rights are weak.

  3. Errors in representation, binding authority, and authorization: If the authorization definition is missing in the electronic application, the process ends before it even begins.

  4. Ignoring public debt/social security debt risk: In markets like LPG, "debt-free" conditions can be decisive in extension/transaction phases.

  5. Neglecting post-licensing compliance: Obtaining a license is “the beginning”; reporting, market conduct rules, and contract management protect the license.

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         A license is not a "document" but a "compliance architecture"

      In Turkey, licensing in energy markets is governed by different sets of regulations, ranging from electricity and natural gas to petroleum, LPG, and charging services. However, the common denominator is clear: the right license type + the right company structure + the right permit inventory + the right application technique + post-licensing compliance.

     In production projects in particular the preliminary licensing phase acts as a filter, testing the viability of the investment.
     In natural gas, regulations such as response times for applications necessitate the disciplined preparation of the application file.