On 24 September 2026, the Türkiye Green Taxonomy Regulation was published in the Official Gazette and took effect the same day. According to the announcement from the Ministry of Environment, Urbanisation and Climate Change, the aim is to define in a common language which investments and activities count as environmentally sustainable, and to reduce the risk of greenwashing.
As an SME manufacturer, your first question is probably whether this puts an obligation on you. The short answer is no, not directly. The longer answer is about what your bank will ask of you, and that part can start taking shape well before 2029. This article walks through the regulation’s main lines, who reports what and when, and what you can do now.
What is a taxonomy and why is it needed?
A taxonomy is a classification system that lists the criteria an economic activity must meet to be called “green”. The logic is simple. When a bank says it has made a green loan, it should be clear what that claim is measured against. Without criteria, everyone uses their own reading, and neither investors nor borrowers know what is actually green.
The regulation sets those criteria. In our earlier piece on the National Green Finance Strategy, we described how the taxonomy would enter banks’ credit assessments. The regulation completes the legal basis of that framework.
Three conditions for an activity to be “aligned”
Under the regulation, an economic activity counts as taxonomy-aligned only if all of the following hold together:
- It makes a substantial contribution to at least one of the six environmental objectives.
- It does no significant harm to any of the other objectives.
- It complies with minimum social safeguards.
The six objectives are:
- Mitigation of greenhouse gas emissions
- Adaptation to climate change
- Sustainable use and protection of water and marine resources
- Transition to a circular economy
- Pollution prevention and control
- Protection and restoration of biodiversity and ecosystems
The second condition is the one that confuses people most on the shop floor. If a plant cuts its emissions through an energy efficiency investment but worsens its wastewater, it is not aligned. One good result is not enough. You also need to show you are not causing harm elsewhere.
Scope: 16 sectors, 137 activities
According to the announcement, the technical screening criteria cover 16 sectors and 137 economic activities. The list started from the activities in the EU Taxonomy, and agriculture and tourism were added given Türkiye’s economic structure. The announcement also says new sectors and activities will be defined later.
The Climate Change Directorate sets the criteria and publishes them on its official website. Under the regulation text, updated criteria are published by 15 December each year and apply from the year after the update. Production activities based on solid fossil fuels are not treated as environmentally sustainable.
Check the Directorate’s published list to see which activity codes cover your company. Not being on the list does not mean you are “not green”. It only means you do not appear as an “eligible activity” in taxonomy reports.
Who has to report?
Under Article 13, the picture looks like this:
| Entity | Reporting | Note |
|---|---|---|
| Companies carrying out Annex-1 activities (real sector) | Voluntary (“may report”) | Templates to be set by the Climate Change Directorate |
| Banks, insurance and reinsurance companies, pension companies, brokerage firms, portfolio management companies, investment trusts | Mandatory | Transition relief until 1 January 2029 |
Procedures for financial institutions will be set separately by the CMB, the BRSA and the ISEDDK.
The key sentence is this. Financial institutions can request taxonomy reports from other companies for transactions that may feed into their own reporting. No article tells an SME directly to submit a report, but your bank may ask for data so it can classify you as “aligned” in its loan portfolio. The bank’s 2029 report will rest on the data of the companies it lends to today.
Indicators that go into the report
Per the regulation text, the key performance indicators cover the share of turnover, capital expenditure and operating expenditure that comes from Annex-1 activities. The report answers three questions with numbers:
- What share of your turnover comes from eligible and aligned activities?
- What share of your capital expenditure went into those activities?
- What share of your operating expenditure relates to them?
The text also says that if an activity’s share of turnover, capex or opex is below 10 percent of the total, the related indicator may be left out of the report. Reports are uploaded to the system by the end of the sixth month after the reporting period closes, and taxonomy reports uploaded to the system will be publicly available. A wrong or unsupported statement would therefore be visible.
There is an enforcement angle as well. Those who do not provide the required notifications, information and documents face administrative fines under the Climate Law. The regulation does not state a fixed amount and refers to the relevant articles of that law. Check the provision that applies to you in the Official Gazette text and, if needed, with your legal adviser.
What changes in a bank meeting?
Expect three concrete effects.
Extra questions in loan applications. When you request an investment loan, you may be asked which activity the equipment falls under, how it contributes to energy efficiency and what its environmental impact is. A file that answers with numbers moves faster.
Evidence for green loans. For loans labelled green, banks will need a taxonomy basis. Projects that provide one may be preferred. We collected the current credit lines and funds in our green transition financing guide.
A greenwashing check. The regulation defines greenwashing as the deceptive use of marketing and similar methods to make a product or service appear more environmentally friendly than it is. When your catalogue, quotes and website say “eco-friendly”, measured data needs to stand behind the words.
Six steps you can take today
- Map your activity. Check the Directorate’s published list for the activity codes that cover you. If you have several product lines, check each one separately.
- Collect energy and emissions data. Gather meter readings, invoices and production volumes in a monthly table. This data feeds the carbon footprint calculation, CBAM and the taxonomy alike.
- Break down turnover, capex and opex. If your accounting does not separate by activity, start coding now. Splitting retroactively is hard.
- Run a “do no significant harm” check. Keep records of water use, waste, chemicals and emission permits close at hand. Records you already keep under the zero waste regulation help here.
- Gather social safeguard records. Occupational health and safety, working hours and pay records prove the third condition. Keep them in one dated place, not scattered folders.
- Talk to your bank. Ask what format and frequency of data they will expect. The financial side of the regulation will be completed by CMB, BRSA and ISEDDK rules, and banks will build their preparations on them.
Where İkiz Eksen fits in
Taxonomy, CBAM and CSRD look like separate rules written by different bodies, but they ask for the same data: energy, emissions, production, waste and a financial breakdown by activity. İkiz Eksen works on a measure, software and compliance chain. Data is taken from the shop floor, consolidated in a single system using Qera’s enterprise software experience (550+ customers across 15+ sectors and 100+ ERP implementations), and then converted into the output your bank or regulation asks for. The infrastructure runs on Microsoft Azure, and delivery is turnkey across Türkiye.
If you want to see first what data you already have, visit our digital transition and green transition pages, or get in touch.
Frequently Asked Questions
Is the regulation mandatory for small businesses?
No. Reporting is voluntary for companies carrying out Annex-1 activities. The obligation applies to banks, insurance and pension companies, brokerage firms, portfolio management companies and investment trusts. The regulation text has no separate provision specific to SMEs.
When does reporting start for financial institutions?
Under the transitional article, financial institutions do not have to report under the taxonomy until 1 January 2029. The CMB, BRSA and ISEDDK will set the procedures separately.
Can my bank ask me for taxonomy data?
The regulation allows financial institutions to request reports from other entities for transactions that may feed into their own reporting. In practice, expect questions about activity, energy and emissions data in your loan file. It is safest to ask your bank for the request in writing.
Is the taxonomy the same as CBAM?
No. CBAM is a border mechanism based on the embedded emissions of certain products exported to the EU. The taxonomy is a classification that sets the criteria for activities and investments in Türkiye to be called green. Because both ask for energy and emissions data, one measurement setup can serve both needs. For the CBAM side, see our definitive period article.
What if my activity is not on the list?
If your activity is not in Annex-1, you do not count as an eligible activity in taxonomy reports, which does not mean your activity is harmful. According to the announcement, new sectors and activities will be added later. Follow the current list on the Climate Change Directorate’s website.
Sources: the announcement of the Ministry of Environment, Urbanisation and Climate Change (iklim.gov.tr) and the Türkiye Green Taxonomy Regulation published in the Official Gazette on 24 September 2026. Before making a decision for your own case, verify the regulation text and the Directorate’s current publications.