The Türkiye Green Taxonomy Regulation was published in the Official Gazette of 24 September 2026 (No. 33380) and entered into force the same day. Issued by the Climate Change Presidency under Climate Law No. 7552, it sets up the national classification system that decides when an economic activity counts as “environmentally sustainable”. The debate usually centres on cement, energy and steel, yet the annex of activities also lists data centres, climate-data software, second-hand marketplaces, product-as-a-service models and insurance against climate risks. Because banks must report under the taxonomy from 1 January 2029, every company that seeks financing will meet this classification at the credit desk. Ahead of COP31 in Antalya in November, this guide explains what the regulation means for startups, fintechs and companies raising capital in Türkiye.
What the taxonomy does and does not do
The taxonomy is a classification system: it measures whether specified activities make a “substantial contribution” to environmental objectives against common technical criteria. The purpose clause lists three aims: supporting activities aligned with sustainable development, encouraging financing flows into sustainable investment and preventing greenwashing (Article 1). Four points should be clear from the start:
- It is not a permit regime. No investment needs a “green activity permit”; permits under environmental and energy legislation are still required separately.
- Reporting is voluntary for companies. Companies carrying out at least one Annex 1 activity “may” report using templates the Presidency will publish (Article 13(1)).
- It is mandatory for financial institutions, but from 2029. Brokerage firms, investment trusts and portfolio management companies, banks, and insurance, reinsurance and pension companies must report under procedures set by the Capital Markets Board (SPK), the Banking Regulation and Supervision Agency (BDDK) and the Insurance and Private Pension Regulation and Supervision Agency (SEDDK); under the transitional provision the obligation does not start before 1 January 2029.
- Production activities using solid fossil fuels never qualify as sustainable (Article 11(2)). It is the only absolute exclusion in the main text.
Eligible is not the same as aligned
The regulation rests on two concepts. An eligible economic activity is an activity listed in Annex 1 (Article 4(1)(ü)). An aligned economic activity is an eligible activity that meets all three conditions in Article 6:
- a substantial contribution to at least one of the six environmental objectives,
- no significant harm to any other environmental objective, and
- compliance with minimum social safeguards.
The six objectives are (Article 7): greenhouse gas emission reduction, climate change adaptation, sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control, and protection and restoration of biodiversity and ecosystems. “Substantial contribution” and “no significant harm” are measured against technical screening criteria set by the Presidency (Articles 8, 9 and 11); a well-meant environmental policy is not enough on its own. Minimum social safeguards are defined as the procedures ensuring compliance with the ILO’s ten fundamental conventions, the Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights and national labour and social security law (Article 10).
In practice: being listed in Annex 1 does not make an activity “green”; it is only the starting point of the assessment. The assessment is made activity by activity, not company by company. One company can have an aligned activity, a merely eligible one and a third that is not listed at all.
What Annex 1 holds for technology and service companies
Annex 1 contains separate activity lists for each of the six objectives. According to the Presidency’s announcement, the criteria cover 137 economic activities in 16 sectors; the list starts from the EU Taxonomy and adds agriculture and tourism as Türkiye-specific sectors. Alongside heavy industry and energy, the following items matter directly to technology and service companies:
| Objective | Annex 1 activity | Relevant for |
|---|---|---|
| Emission reduction (A) | 8.1 Data processing, hosting and related activities (transitional activity) | Data centre, cloud and hosting companies |
| Emission reduction (A) | 8.2 Data-driven solutions for greenhouse gas emission reductions (enabling) | Carbon accounting, energy management and emissions-monitoring software |
| Emission reduction (A) | 9.1 Market research, development and close-to-market innovation (enabling); 9.3 professional services related to the energy performance of buildings | R&D-intensive startups, energy-efficiency consultants |
| Climate adaptation (B) | 8.2 Computer programming, consultancy and related activities; 8.3 programming and broadcasting (enabling); 9.2 engineering and technical consultancy for climate adaptation | Software and consultancy firms, climate-risk analytics |
| Climate adaptation (B) | 11.1 Non-life insurance: underwriting of climate-related perils; 11.2 reinsurance (enabling) | Insurers and insurtech |
| Water and marine resources (C) | 4.1 Data-driven IT or operational technology solutions for leakage reduction (enabling) | Smart metering, IoT and water-tech startups |
| Circular economy (Ç) | 4.1 Data-driven IT/OT solutions (enabling); 5.1 repair, refurbishment and remanufacturing; 5.2 sale of spare parts; 5.4 sale of second-hand goods; 5.5 product-as-a-service and other circular, results-oriented service models; 5.6 marketplace for the trade of second-hand goods for reuse (enabling) | Refurbished electronics, rental, subscription and second-hand marketplaces |
| Emission reduction and adaptation (A, B) | 7.1-7.7 construction and real estate; 7.4 EV charging stations; 6.4 personal mobility devices and cycle logistics | Proptech, charging infrastructure and micromobility companies |
The “transitional” and “enabling” labels matter. A transitional activity has the lowest emission levels in a sector where low-carbon alternatives are not yet available and does not hamper the development of those alternatives (Article 4(1)(ı)); data centres fall into this category. An enabling activity facilitates other activities’ substantial contribution, has a substantial positive life-cycle impact and does not encourage the use of carbon-intensive assets (Article 4(1)(k)). Climate-data software and second-hand marketplaces sit in this second group: a startup that does not reduce emissions itself can still come within the taxonomy if it enables its customers’ reductions.
The technical screening criteria will be published on the Presidency’s website (Article 11(4)); updates are announced by 15 December each year and apply from the following year (Article 11(5)-(6)). Whether a given activity is aligned can only be assessed concretely once the criteria text for that activity is out; until then the useful work is mapping activities to Annex 1 and starting to collect the necessary data.
Indicators and the ten per cent rule
A taxonomy report is built on three key performance indicators: the share of revenue, capital expenditure and operating expenditure derived from eligible or aligned products and services (Article 12(2)(a)). Banks, capital markets institutions and insurers will also report ratios showing how far their own activities contribute to the environmental objectives (Article 12(2)(b)-(ç)).
Voluntary reporters get one relief: where the share of revenue, capital expenditure or operating expenditure derived from eligible Annex 1 activities is below 10% of the total, they may leave that indicator out of the report (Article 13(8)). Each indicator is calculated separately, and the ratio is measured by eligible activities, not aligned ones.
An example: a software company has annual revenue of TRY 80 million, of which TRY 6 million comes from an emissions-monitoring module it sells to customers (Annex 1 A 8.2); the rest comes from unlisted products. Its eligible revenue share is 7.5%, so it may omit the revenue indicator. In the same year, TRY 4 million of its TRY 10 million capital expenditure went into developing that module, an eligible capex share of 40%. No relief for capex. Low on revenue and high on investment is a typical picture for a growth-stage tech company, and it is also the summary of the story to tell investors.
When reports are filed, where and who sees them
- Timing: the report is uploaded to the Online Taxonomy Management System by the end of the sixth month after the end of the financial reporting period, or of the special accounting period where one is used (Article 13(3)). For a calendar-year company that means 30 June. The report covers the year before the reporting date (Article 13(7)).
- Publicity: reports uploaded to the system are public by default (Article 20(3)). Supporting information and documents outside the report may be shared with third parties only with the company’s consent (Article 22(1)). A startup reporting voluntarily should plan in advance how it will summarise product or customer data that is commercially sensitive.
- Verification and transition plan: the Presidency will set the verification procedures (Article 15). A taxonomy transition plan setting out the company’s strategy for meeting the criteria complements the report (Article 14). A target in a transition plan does not show alignment in the current period.
Your bank will ask you for taxonomy data
For companies seeking financing, the key provision is Article 13(4): financial institutions subject to reporting may ask their customers to report under the regulation for business and transactions relevant to their own reporting. The regulation also states that banks will calculate their own indicators from their customers’ current data (Article 12(3)). From 2029, a bank’s report will largely be fed by the reports of the companies it lends to.
The request is not limited to loans labelled “green”. The expected picture: taxonomy indicators will appear as KPIs and reporting covenants in sustainability-linked loans and green loans; credit approval will come with Annex 1 mapping and data questionnaires; foreign investors and EU customers already ask for EU Taxonomy data. How much of a loan counts as aligned financing in the bank’s report will depend not only on the customer’s indicators but also on the use of proceeds and the bank-specific calculation rules that SPK, BDDK and SEDDK will set (Article 13(5)).
Three contractual points follow. First, a representation that “our activity is taxonomy-aligned” must be kept apart from an undertaking to “become aligned by a given date”: the first is a warranty about a present fact, the second a future obligation. Second, the contract should state which period the data covers, who verifies it and how the bank may use it in its own report and in the public system. Third, because the criteria can be updated every year, the contract should say how KPIs are recalibrated if the criteria change during the term.
Greenwashing and sanctions
The regulation defines greenwashing as the deceptive use of public relations, financing, advertising or marketing methods to create the perception that a company’s products or services contribute to environmental objectives, do no significant harm and respect social safeguards (Article 4(1)(z)). The definition shows plainly the risk of using “taxonomy-aligned” as a marketing label.
On sanctions, Article 23 applies paragraphs 6, 9 and 11 of Article 14 of Climate Law No. 7552 to those reporting under Article 13 who fail to provide the notifications, information and documents required for reporting. Because Article 13 covers voluntary reporting too, a company that chooses to report also enters this regime. Article 14(6) of the Law imposes a TRY 170,000 administrative fine on individuals and private legal entities that fail to provide information or documents or make misleading statements; revalued for 2026, the amount is TRY 213,333. If the act is repeated within three years, the fine is increased by one fold on the first repetition and two fold on subsequent ones (Article 14(9)), and the fine for each act may not exceed TRY 50 million (Article 14(11)). Separately, green claims to consumers in the EU have been governed by Directive (EU) 2024/825 since 27 September 2026; see our climate fintech note.
What startups, fintechs and companies raising finance should do
Activity mapping: compare your current and planned products and services with Annex 1. What the company actually does decides, not the objects clause in its articles. Do not skip the “enabling” items: software, data and platform businesses often fall there.
Data infrastructure: set up accounting that can split revenue, capital expenditure and operating expenditure by activity now. The 10% calculation and every data point you give your bank depend on that split. Companies within the scope of the Turkish Sustainability Reporting Standards (TSRS) will use the same data in two reports.
Social safeguards: keep implementation records alongside your policies on occupational health and safety, pay, discrimination and supply-chain risk; Article 10 asks for working procedures, not a policy document.
Contracts and communications: separate alignment representations from future commitments in loan and investment documents; in marketing and investor materials, use “green”, “sustainable” or “taxonomy-aligned” only after the criteria are published and an assessment has been made, and with the basis stated.
Fintechs and financial institutions: use the transition period to build the processes, data forms and contract templates for collecting customer data for 2029 reporting. If you build a product that collects, maps or calculates taxonomy data, that product may itself fall under Annex 1 A 8.2. Our fintech team advises on the legal design of these processes.
Frequently asked questions
Does our company have to file a taxonomy report?
No. Reporting is voluntary for companies carrying out Annex 1 activities (Article 13(1)). The obligation applies to brokerage firms, investment trusts, portfolio management companies, banks, and insurance, reinsurance and pension companies, and does not start before 1 January 2029. Your bank or institutional investor may still ask you for taxonomy data (Article 13(4)).
If our activity is listed in Annex 1, is it green?
No. Being listed only makes the activity “eligible”. To be “aligned”, it must make a substantial contribution to an environmental objective under the technical screening criteria, do no significant harm to the others and comply with minimum social safeguards, all at the same time (Article 6).
Can software and data companies come within the taxonomy?
Yes. Annex 1 includes data processing and hosting, data-driven solutions for emission reductions, programming and consultancy for climate adaptation, data-driven IT/OT solutions for leakage reduction and the circular economy, and second-hand marketplaces. Several of these are classified as enabling activities.
How is the ten per cent rule calculated?
A voluntary reporter may omit an indicator where the share of revenue, capital expenditure or operating expenditure derived from eligible Annex 1 activities is below 10% of the total (Article 13(8)). Each indicator is calculated separately, and the ratio is measured by eligible, not aligned, activities.
What is the sanction for an inaccurate taxonomy report?
Failing to provide the information and documents required for reporting, or making misleading statements, attracts an administrative fine under Article 14(6) of the Climate Law; the amount is TRY 213,333 for 2026. The fine increases on repetition within three years and is capped at TRY 50 million per act.
Sources. Türkiye Green Taxonomy Regulation, Official Gazette 24.9.2026, No. 33380 (in Turkish); Annex 1 to the Regulation: sectors and activities within the taxonomy (in Turkish); Climate Law No. 7552, Official Gazette 9.7.2025, Articles 8(1)(c) and 14; Communiqué 2026/1 on Administrative Fines under Climate Law No. 7552, Official Gazette 27.12.2025, No. 33120; Climate Change Presidency announcement, September 2026.
