The January 2025 EMRA regulation on bilateral electricity trading represents the most significant structural intervention in Turkey's renewable energy contracting landscape in over a decade. Its effects are already being felt across wind, solar, and hydro PPA negotiations.
Key Regulatory Changes
The regulation introduces mandatory disclosure requirements for contract pricing, caps on certain penalty structures, and new provisions governing the termination of long-term supply agreements. Contracts signed under the pre-2025 framework may now contain clauses that conflict with the updated regulatory environment.
Pricing Models Under Pressure
Fixed-price PPAs are being stress-tested by inflation, currency movements, and grid balancing costs not anticipated at signing. The regulation provides a limited hardship adaptation mechanism, but its scope is narrowly defined and subject to EMRA approval.
What Companies Should Do Now
We recommend an immediate audit of existing PPA portfolios against the new regulatory framework, focusing on termination trigger compatibility, force majeure clause adequacy, pricing adjustment mechanisms, and dispute resolution provisions.