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Amendments to the Charging Service Regulation

By Semiz Law Firm

New Developments

The Regulation Amending the Charging Service Regulation (the “Amending Regulation”), prepared by the Energy Market Regulatory Authority (“EMRA”), was published in the Official Gazette dated 23 March 2026 and numbered 33202. The Amending Regulation introduces comprehensive amendments to the Charging Service Regulation published in the Official Gazette dated 2 April 2022 and numbered 31797 (the “Regulation”).

The Amending Regulation brings numerous innovations, including the inclusion of mobile charging stations within the regulatory framework, the recognition of roaming mechanisms between charging network operators, updated pricing rules, enhanced information security obligations, and the redesign of the open access platform.

Mobile Charging Stations and New Definitions

While mobile charging units were previously excluded from the scope of the Regulation, the Amending Regulation explicitly brings mobile charging stations within its scope. In this context, a mobile charging station is defined as a charging station that is not connected to a fixed electrical installation.

In addition, the following new definitions have been introduced:

  • Smart charging systems: Systems enabling real-time monitoring, control, and adjustment of the amount of energy transferred from the charging unit to the electric vehicle.
  • EPİAŞ: Energy Markets Operation Inc.
  • Roaming agreement: Agreements entered into between charging network operators covering data and payment exchange for the purpose of directly serving each other’s users.
  • Charging point (socket): Connection equipment used to transfer energy from the charging unit to the electric vehicle.

Charging Network and Licensing Provisions

The definition of the charging network has been expanded to include mobile charging stations alongside publicly accessible and commercially operated private charging stations. The Regulation now explicitly states that a charging network is a structure that establishes connections between multiple charging stations through software and hardware support. Charging points at mobile stations will be taken into account for the minimum network establishment obligations.

The rights and obligations of charging network operator license holders have been expanded. License holders are now entitled to enter into roaming agreements, issue invoices for charging services and collect payments from users, and operate mobile charging stations. Operators are required to notify EMRA of roaming agreements within 30 days following execution.

In cases of license granting and termination, the relevant entity’s trade name, registered trademark, and license duration/termination date will be published in the Official Gazette. A new procedure has been established for the transfer of charging stations between networks, requiring both the transferring and receiving operators to notify EMRA electronically.

Pricing and Payment Provisions

The Amending Regulation introduces significant innovations to the pricing regime:

Single price principle: The charging service price shall be applied as the unit energy price transferred to the electric vehicle (TRY/kWh). No additional fees may be charged under any name, such as connection fees, transaction initiation fees, or equipment usage fees.

Price differentiation: At publicly accessible charging stations, price differentiation may only be made between AC charging units, DC charging units, and mobile charging stations. The previous provision allowing different prices for different types and capacities of charging units has been removed.

Loyalty pricing cap: The charging service price applied at publicly accessible stations may not exceed the lowest price offered to loyalty contract users by more than 25%. No separate fee may be charged under loyalty contracts for membership, contract fees, or under any other name.

Location and time-based discounts: Charging network operators may apply discounted prices based on the station’s location and the time of day. When time-based discounts apply, the price at the beginning of the charging session shall be the basis for the fee charged to the user.

Battery level-based termination: Provided that the user is informed in advance, the charging service may be terminated for electric vehicles with a battery level of 85% or above when using DC charging units.

Direct payment requirement on highways: Charging stations newly added to a network at highways under the responsibility of the General Directorate of Highways must provide direct payment through bank/credit card readers or contactless payment devices for at least one DC charging unit of 50 kW or above. No additional fee, commission, or surcharge may be charged for these payment methods. This provision will enter into force on 1 July 2026.

Information Security and Service Quality Obligations

The information security obligations of charging network operators have been significantly enhanced. The software systems used for providing charging services, as well as the IT infrastructure related to charging equipment and remote access processes, must comply with the current version of the TS ISO/IEC 27001 standard. Measures must be taken regarding the prevention of unauthorized access, the use of secure communication channels, authentication and access authorization, and cloud computing security.

Regarding service quality, charging network operators are now required to establish or procure an ISO 18295-certified call center providing uninterrupted 24-hour service. Operators must also provide instant charging services to all users through their website or mobile application, regardless of whether they have a loyalty contract, and must provide real-time information on the availability, status, and pricing of all stations and sockets.

Open Access Platform and Other Provisions

The provisions on the open access platform have been comprehensively revised. The platform, to be established and operated by EMRA, will publish the geographic location, charging unit type, socket count, capacity and type information, availability status, payment method, and pricing information of all publicly accessible charging stations. Operators are additionally required to report the amount of electricity consumed in the course of charging services.

Furthermore, smart charging systems are now permitted at charging stations; station operators may use their own brand alongside the network operator’s brand; and operators have been authorized to take necessary measures to prevent vehicles from blocking charging station parking areas. Green charging station operators that have completed their renewable energy certificate redemption obligations will be published monthly by EPİAŞ.

Effective Date and Transitional Provisions

The provision regarding direct payment at highway stations (Article 21/8) will enter into force on 1 July 2026. All other provisions entered into force on the date of publication (23 March 2026).

Under the transitional provisions, existing charging network operator license holders have been granted 1 year to establish their software systems in compliance with the TS ISO/IEC 27001 certification, and 6 months to fulfil the enhanced service quality obligations (call center, real-time information provision, etc.).

Conclusion

The Amending Regulation introduces comprehensive reforms to the electric vehicle charging service market in Turkiye. The inclusion of mobile charging stations within the regulatory framework, the recognition of roaming mechanisms, and the detailed pricing rules represent significant steps in line with the maturing of the sector.

Charging network operators and station operators should prioritize completing the necessary preparations within the transitional periods, particularly regarding TS ISO/IEC 27001 certification, ISO 18295-certified call center establishment, updates to pricing policies, and the installation of direct payment infrastructure at highway stations.

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