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Environmental Management Services Regulation 2026: What Changed?

Okan Nas
Oct 6
5 min read

An amendment to Turkey's Regulation on Environmental Management Services (Çevre Yönetimi Hizmetleri Hakkında Yönetmelik) was published in the Official Gazette (Resmî Gazete) of 6 October 2026, issue 33392 and entered into force on the same day. Although the rules are addressed to environmental consultancy firms, their effects reach every business that uses those firms: the minimum monthly fee has risen, the minimum time a consultant must spend with a business is now written into the regulation, and a 30-day application window has been introduced for missing EIA (ÇED) procedures or permits. This article summarises what matters for your business in plain language.

Who does the amendment affect?

It affects every business that receives services from an environmental consultancy firm or an environmental officer. Most of the new rules depend on where a business sits under the Regulation on Environmental Permits and Licences (Çevre İzin ve Lisans Yönetmeliği): activities on the EK-1 list (those with a high polluting impact), activities on the EK-2 list, and businesses that appear on neither list but still receive these services. Confirming which list applies to you, from your environmental permit or licence and with your consultant, is the first step to reading the points below correctly.

1. The minimum monthly fee has gone up

The minimum monthly service fee is set as a share of the net minimum wage and is calculated excluding VAT. The shares have changed as follows:

  • Businesses on the EK-1 list: 3/4 of the net minimum wage, up from 1/2

  • Businesses on the EK-2 list and businesses on neither list: 1/2, up from 1/3

  • On top of this, 5% of the relevant unit price is added for each permit or licence subject.

To see what this means today: the net minimum wage for 2026 was announced as TRY 28,075.50. On that basis, the minimum monthly fee, excluding VAT and the permit/licence supplement, comes to roughly TRY 21,057 for EK-1 businesses and roughly TRY 14,038 for EK-2 businesses and those on neither list. These amounts move with the minimum wage; the shares stay fixed.

2. Existing contracts must be renewed by 1 January 2027

Consultancy contracts already in place must be renewed on the basis of the new tariff by 1 January 2027 at the latest. If the fee in your contract is already equal to or above the new minimum tariff, no renewal is needed. The first task, therefore, is to compare the monthly fee in your current contract with the shares above.

Payments are now documented as well: the document showing the payment made by the business is attached to the monthly activity report for that month or the following month. Keeping your invoices and payment receipts in order becomes more important as a result.

3. How many days of service per month?

The regulation now sets a minimum service time:

  • Businesses on the EK-1 list: at least 2 working days per month

  • Businesses on the EK-2 list and businesses on neither list that receive services: at least 1 working day per month

This is the minimum time your consultant must devote to your business. Planning site visits, record checks and reporting around this schedule matters both for meeting the obligation and for being able to demonstrate it during an inspection.

4. Missing EIA or permits: a 30-day application window

The amendment introduces a new concept, non-compliance with mandatory procedures (aykırılık). It covers cases such as an EIA process that was never carried out, an EIA-relevant change that was not notified, operating without a required permit or licence, or not having started the application for one.

The consultant records any such case in the monthly report. If the business does not start the official application process to resolve it within 30 days, the consultant is obliged to notify the competent authority. What is required within 30 days is starting the official process, not completing it. For other nonconformities (uygunsuzluk), the existing 90-day rule continues to apply.

5. Penalties for not receiving services or not providing documents

A new article added to the regulation states the sanctions explicitly. Businesses that are required to receive these services but do not are subject to an administrative fine under Article 20(1)(m) of Environmental Law No. 2872, and businesses that fail to provide requested information and documents are subject to an administrative fine under Article 20(1)(g) of the same law. Sharing the records your consultant asks for on time matters for this reason too.

6. Check your consultant's credentials

Check that the firm you work with holds a valid qualification certificate from the Ministry. In addition, from 1 January 2027 environmental consultancy firms must hold an office registration certificate from the Chamber of Environmental Engineers (ÇMO büro tescil belgesi).

A short checklist for businesses

  • Is your business on EK-1, on EK-2, or on neither list? Confirm it from your certificate and with your consultant.

  • Compare the monthly fee in your current contract with the new share; if it is lower, renew before 1 January 2027.

  • Keep your payment documents in order so they can be attached to the monthly report.

  • Plan your consultant's monthly visit schedule together, in line with the new minimum time.

  • Check whether your recent reports record a missing EIA, permit or licence; if so, start the official application within 30 days.

  • Check the consultancy firm's qualification certificate and ÇMO office registration.

A note for businesses in Antalya

You can find the details of our environmental consultancy service on our website.

For Antalya businesses that run on a tourism season, timing matters. Putting the 1 January 2027 renewal deadline in your calendar ahead of time, alongside your budget cycle and the end of your season, avoids a rush in the final weeks.

Frequently Asked Questions

When does the new minimum fee apply?

The amendment entered into force on 6 October 2026, the day it was published in the Official Gazette. Existing contracts must be renewed under the new tariff by 1 January 2027 at the latest; contracts whose fee is already equal to or above the tariff do not need to be renewed.

What if my business is on neither EK-1 nor EK-2?

Businesses that are on neither list but receive environmental consultancy services follow the same rule as EK-2 businesses for fees and time: a minimum monthly fee of 1/2 of the net minimum wage and at least 1 working day of service per month.

What is the difference between aykırılık and uygunsuzluk?

Aykırılık refers to fundamental gaps such as operating without an EIA, permit or licence, or not having started the application for one, and the official application process must be started within 30 days. For nonconformities (uygunsuzluk), the existing 90-day rule continues to apply.

Do the example amounts include VAT?

No. The regulation defines the minimum fee excluding VAT, and the 5% added for each permit or licence subject is not included in the example amounts either. The best approach is to calculate the amount for your business together with your consultant.

Conclusion

This amendment makes environmental consultancy more measurable: the minimum fee, the minimum time and the reporting of gaps are now clearly set out in the regulation. For businesses, the most urgent task is to review the current contract before 1 January 2027 and to follow up on any gaps recorded in the reports. You can always contact us with your questions.

Written by Okan Nas, Environmental Engineer, Asel Çevre Danışmanlık.

 
 
 

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