The Regulation Amending the Charging Service Regulation (the “Amending Regulation”) entered into force upon its publication in the Official Gazette on 23 March 2026 (No.33202). The Amending Regulation introduces amendments to various provisions of the Charging Service Regulation (the “Regulation”). While most amendments entered into force upon publication, a specific provision concerning charging stations will take effect on 1 July 2026.

Considering the recent developments observed in the electric vehicle ecosystem, it appears that the regulatory framework governing charging infrastructure has been brought back onto the agenda for reconsideration, both in its technical and commercial dimensions. In this context, it may be understood that, through the Amending Regulation, the scope of charging network operation activities has been expanded, and new obligations and standards have been introduced in areas such as data and system security, user experience, and market transparency.

In this article, the amendments are examined on an article-by-article basis, and the scope of the relevant regulations, as well as their potential implications in practice, are evaluated within the framework of the existing legislation.

Expansion of Purpose and Scope (Article 1)

The explicit inclusion of mobile charging stations within the scope of the Regulation stands out as one of the notable amendments. It may be considered that this provision seeks to ensure that mobile solutions already in practical use are brought within the regulatory framework.

This expansion of scope may provide a clearer regulatory basis for mobile charging activities in terms of licensing, supervision, and technical standards.

Systematic Revision in the Definitions (Article 3)

It may be stated that the amendments made to the definitions article do not merely constitute a technical update but also carry a nature that reshapes the scope of application of the Regulation.

First, with the removal of the phrase “by the Presidency of Digital Transformation Office” from the definition of the Information and Communication Security Guide, it appears that the institutional reference of the guide has been moved to a more general framework. This amendment may allow for a more flexible interpretation of technical standards without being tied to a specific institution.

In addition, with the introduction of definitions such as smart charging systems, mobile charging station, EPİAŞ, roaming agreement, and charging point (socket), it is understood that digitalization, data management, and integration processes between charging networks are being defined at the regulatory level.

From this perspective, the amendment may be considered as aiming to establish a legal infrastructure parallel to the technical transformation of the market.

Clarification of the Scope of Exemptions (Article 5)

With the amendment made to the exemptions article, the scope of the provision concerning private charging stations that do not carry out commercial activities has been expanded. In particular, the addition of the phrase “units installed for one’s own use, whether directly or through third parties” may be regarded as a step aimed at eliminating potential ambiguities that may arise in practice.

This amendment may contribute to a clearer delineation of the boundary between individual use and commercial activity.

Transparency and Predictability in Licensing Processes (Articles 8 and 11)

Two key amendments stand out in the regulations concerning licensing processes.

First, an explicit provision has been introduced stipulating that license-related information will be published in the Official Gazette. This arrangement may be significant in terms of ensuring the public visibility of licensed activities and enhancing market transparency.

Second, it appears that the provision in the previous regulation concerning the timing of the payment of license fees which could lead to differences depending on the application or decision date, has been abolished. Instead, license fees applicable for the following year will be determined by the Energy Market Regulatory Authority Board (“Board”) by the end of December each year, published in the Official Gazette, and announced on the Board’s website. This amendment may be regarded as aiming to reduce uncertainties in practice regarding license fees.

Notification Mechanism Regarding the Termination of Licenses (Article 14)

An explicit provision has been introduced requiring that information concerning legal entities whose licenses have expired or been revoked be published in the Official Gazette and announced on the Board’s website.

This provision may enable market participants to more closely monitor the licensing status of other actors and may contribute to increasing the level of transparency within the sector.

Expansion of the Charging Network Structure (Article 15)

It appears that the amendments introduced to the provisions concerning the charging network have expanded the scope of the system.

Within this framework, with the amendment introduced under Article 15/1, the scope of the charging network has been extended to include mobile charging stations, as well as publicly accessible and commercially operated private charging stations that establish connections between multiple charging stations through software and hardware infrastructure for the purpose of providing charging services.

In addition, with the amendment introduced under Article 15/2, the emphasis on publicly accessible charging stations has been strengthened. Furthermore, with the addition of Article 15/6, it has been stipulated that charging points within mobile charging stations will also be considered within the scope of minimum network obligations.

These amendments may be considered as aiming to ensure that charging infrastructure is addressed within a more integrated and holistic system.

Expansion of the Rights and Obligations of License Holders (Article 16)

The amendments introduced under Article 16 appear to be of a nature that may directly affect the commercial and operational aspects of charging network operation.

In this context, it is understood that license holders have been granted the rights to provide services by making their charging networks available for use, to enter into roaming agreements, to issue invoices to users and collect charges, and to operate mobile charging stations.

On the other hand, a new obligation has been introduced requiring that roaming agreements be notified to the Board within 30 days.

These arrangements may be understood as aiming to support market integration while simultaneously strengthening the supervisory role of the Board.

Data Reporting and Green Charging (Article 16/A)

Under the newly introduced provision, it has been stipulated that, for all electricity subject to charging services at green charging stations, the redemption of YEK-G certificates is mandatory, and that charging network operators are required to publish data flows via EPİAŞ and notify the Board accordingly.

This provision may be considered as aiming to establish a data-driven monitoring mechanism, particularly within the context of carbon footprint tracking and sustainability policies.

Expansion, Reduction and Mobile Charging Stations (Article 17)

When the amendments introduced under Article 17 are examined, it may be observed that the management of charging networks is evolving towards a more dynamic, data-driven, and transferable structure.

At the outset, although the phrase “if the operator intends to add a charging station” has been retained in the provisions governing application procedures, a new requirement has been introduced under the second paragraph, while the scope of information to be submitted remains largely unchanged. Accordingly, it has been explicitly regulated that charging stations deemed appropriate by the Board will be published on the free access platform on a “per-socket and per-power basis” for each station.

Considering that this level of detail was not explicitly emphasized under the previous framework, this amendment may be understood as aiming to enhance transparency regarding charging infrastructure and to enable users to make choices based on technical capacity.

In addition, one of the most notable structural amendments is the new regulation introduced under Article 17/6. With this provision, for the first time, it has been explicitly made possible for a charging station to be transferred from one charging network operator to another. However, this transfer process has not been left as a simple commercial transaction; rather, it has been made subject to a multi-stage process involving notification to the Board, approval by the Board, notification to the relevant distribution system operator, and the cancellation and reissuance of the relevant documentation.

Similarly, with Article 17/7, a separate notification regime has been introduced for the operation of mobile charging stations. Accordingly, operators are required to notify the Board in advance and submit operational and technical details, including geographical areas of operation.

Taken together, these amendments may be considered as strengthening both transparency and regulatory oversight.

Information Security (Article 18)

It is understood that the amendments introduced under Article 18 require compliance with TS ISO/IEC 27001 standards and mandate the implementation of technical measures relating to data security and access control.

Interoperability and Smart Systems (Article 19)

When the amendments introduced under Article 19 are examined, it may be observed that the existing interoperability-based structure has been preserved, while being further developed through additional provisions.

In particular, with the addition of new paragraphs, it is understood that smart charging systems have been formally incorporated into the regulatory framework, allowing for more efficient use of power and enhanced user information.

Furthermore, the Board has been granted powers to determine the procedures and principles governing roaming relationships and to define the relevant technical and commercial protocols.

These developments may be considered as strengthening both technical integration and market standardization.

Certification (Article 20)

The certification mechanism continues to serve as the principal framework governing the relationship between charging network operators and charging station operators.

However, with the introduction of the new provision, it has become possible for both the network operator’s brand and the station operator’s brand to be used at charging stations.

While this does not alter the legal nature of the certification relationship, it may be considered as introducing greater commercial flexibility.

Charging Stations (Article 21)

The amendments introduced under Article 21 appear to preserve the existing framework while introducing additional standardization, particularly in relation to metering and payment infrastructure.

In particular, it has been made mandatory to provide direct payment options in certain high-capacity charging units, especially those located on highways, without requiring membership or additional contractual arrangements.

It is also explicitly regulated that no additional fees may be charged for such payment methods.

Installation of Charging Stations (Article 22)

The amendments under Article 22 appear to introduce a more structured and digitalized application process.

In particular, it is understood that applications are now required to be submitted electronically, that evaluation timelines have been clearly defined, and that documentation processes have been standardized

In addition, limitations have been introduced on the discretion of network operators, and obligations to provide justification for rejections have been strengthened.

Operation of Charging Stations (Article 23)

Article 23 regulates the fundamental obligations regarding the operation of charging stations, service continuity, user rights, and the responsibilities of operators. While the existing regulatory framework is preserved, it appears that, with the amendments introduced, certain aspects, particularly the legal basis of operational activities and on-site practices have been clarified.

Within this scope, with the amendment introduced under Article 23/1, it has been explicitly stipulated that the activities of stations providing charging services are subject to the provisions of the Regulation on Workplace Opening and Operating Licenses. Through this regulation, it is understood that charging stations are to be evaluated not only within the scope of energy legislation but also within the general regime governing workplace opening and operation. This approach may be considered as contributing to the establishment of consistency in implementation, particularly in permit and licensing processes with local authorities.

In addition, within the scope of the Article, the principle of service continuity at publicly accessible charging stations is maintained, and it is regulated that services must be provided uninterruptedly except in cases of force majeure or justified reasons not attributable to the license holder. However, it is also understood that charging stations located within facilities such as hotels, restaurants, and shopping centres may provide services limited to the operating hours of the relevant establishment.

Furthermore, the obligation to immediately take out of service charging stations that pose a risk to life and property safety continues to apply, and the use of such stations is not permitted until safety is re-established. In addition, the principle of providing services to users in equal circumstances without discrimination is also preserved.

Within the scope of obligations relating to informing users, it is regulated that information regarding complaint and application mechanisms, as well as the types and capacities of charging units, must be presented in a clear and understandable manner on or near the station.

With the newly introduced Article 23/6, it appears that certain powers have been granted to operators in relation to parking violations that prevent the actual provision of charging services. Accordingly, charging network operators or charging station operators may take the necessary measures to prevent vehicles from being parked in a manner that obstructs charging services in parking areas designated for electric vehicles, and may issue warnings and provide information in this regard. In addition, it is regulated that operators may apply to the relevant authorities for the adoption of measures to prevent vehicles other than those receiving charging services from parking in such areas. This provision may be considered as a practical tool aimed at ensuring the effective use of charging infrastructure, particularly in areas with high utilization.

Pricing and Disclosure (Article 25)

Article 25 sets out the framework governing how charging service prices are determined, disclosed, and applied, while maintaining the principle of pricing freedom. Although operators continue to enjoy flexibility in setting prices, the Regulation preserves key safeguards such as transparency, comparability, and the obligation to inform users in advance.

The recent amendments suggest a shift toward a more streamlined pricing model, particularly through the simplification of pricing components and the adoption of a single-price structure. In this context, it is explicitly stipulated that users may not be charged additional fees, such as connection fees, session initiation fees, or equipment usage fees beyond the amount calculated based on the unit energy price. This approach may be viewed as strengthening price transparency and enhancing predictability from the user’s perspective.

In parallel, the amendment introduced under Article 25/2 requires that reservation and idle occupancy (overstay) fees be disclosed alongside charging prices. This indicates an expectation that all cost elements associated with the service, not only the energy price, be communicated to users clearly, simultaneously, and in an accessible manner.

The amendment under Article 25/4 further clarifies the boundaries of price differentiation. Under the revised framework, differentiated pricing may only be applied between AC and DC charging units, as well as between fixed and mobile charging stations. This limitation may be considered as a measure aimed at reducing the risk of discriminatory pricing practices among comparable services.

In addition, Article 25/7 introduces a cap mechanism applicable to publicly available prices. Under this provision, the price offered to the public may not exceed the lowest price provided under a loyalty scheme by more than 25%. The Regulation also makes clear that no additional charges such as membership or similar fees, may be imposed within the scope of such arrangements. Taken together, these measures may be understood as seeking to limit excessive price divergence to the detriment of users.

Another notable amendment is introduced under Article 25/11, which allows operators of DC fast charging units to terminate charging sessions once a vehicle’s battery level reaches 85%, provided that users are informed in advance. This provision appears to be designed as a capacity management tool, particularly in high-demand charging environments.

Finally, Article 25/12 explicitly permits the use of location and time-based dynamic pricing. Charging network operators may therefore apply different pricing depending on the station’s location and the time of use. However, the Regulation requires that the price applicable at the moment the charging session begins being fixed as the basis for billing and reflected accordingly to the user. The obligation to disclose such pricing and to notify the Board also remains in place.

User Complaints (Article 28)

The amendments introduced under Article 28 suggest a notable strengthening of the framework governing the management of user complaints, particularly along the axes of digitalization, real-time accessibility, and service continuity.

Under the revised framework set out in Article 28/1, charging network operators are required to establish, or procure, a call centre certified under ISO 18295 capable of providing uninterrupted 24/7 service. This approach may be understood as aiming not only to ensure that user complaints are received, but also that they are managed in accordance with defined professional standards.

In addition, it is observed that complaint handling is no longer limited to call centre channels. Instead, operators are required to establish a system through which users can access, submit, and track their complaints via websites and mobile applications in real time. In this context, it is clearly set out that all users regardless of whether they are part of a loyalty scheme must be able to access these digital channels.

Another notable development concerns the expansion of the scope of information provided to users. Accordingly, charging network operators are required not only to manage complaints but also to make available, via digital platforms and on a real-time basis, information on the status, availability, and pricing of all stations and charging points within their network. This may be considered a significant step toward improving user experience and reducing information asymmetry.

Furthermore, greater clarity has been introduced with respect to the timeframes for handling complaints and requests. Operators remain under an obligation to conclude applications submitted to them within a maximum of 15 business days and to inform the user accordingly. This requirement may be regarded as establishing an important standard in terms of service quality and accountability.

Finally, the obligation to retain records created within this framework for at least two years has been preserved. This may be seen as strengthening both auditability and traceability within the system.

Open Access Platform (Article 30)

The amendments under Article 30 expand the scope of the open access platform and strengthen data transparency.

In particular, it has been made mandatory to publish additional data sets, including energy consumption data.

This development may be considered as supporting both market transparency and regulatory oversight.

Audit and Sanctions (Article 32)

The amendments introduced under Article 32 appear to strengthen institutional coordination in audit and enforcement processes.

In particular, the replacement of “tax office directorate” with “provincial treasury office” reflects an alignment with current administrative structures.

In addition, notification obligations involving multiple authorities have been clarified.

Information Security (Provisional Article 4)

The arrangement introduced under Provisional Article 4 appears to subject existing charging network operators’ compliance with information security obligations to a phased transition period. In this context, it is understood that legal entities holding a charging network operator license as of the effective date are granted a period of one year to ensure that the software and system infrastructure envisaged under Article 18/2 of the Regulation is established in compliance with the TS ISO/IEC 27001 certification standard.

This arrangement may be considered as aiming to ensure the consistent implementation of information security standards across the sector, while at the same time allowing existing operators a reasonable transition period for technical and operational compliance. Considering the increasing importance of data protection and cybersecurity requirements, it may further be observed that the introduction of such certification obligations could contribute to strengthening institutional infrastructure within the sector.

Service Quality (Provisional Article 5)

Provisional Article 5 appears to introduce a transition period to facilitate the compliance of existing charging network operators with newly introduced obligations relating to service quality. In this context, legal entities holding a charging network operator license as of the effective date are granted a six-month compliance period in order to fulfil the obligations set out under Article 28/1 of the Regulation.

This arrangement may be considered as aiming to facilitate the adaptation of existing operators to the new standards introduced, particularly in areas such as the management of user complaints, the establishment of communication channels, and the continuity of service. In this way, it appears that the implementation of the new service quality obligations has been designed to take place within a defined transition period, thereby avoiding sudden disruptions or compliance gaps within the sector.

General Assessment

When assessed in overall terms, it may be observed that the amendments expand the scope of the regulatory framework governing charging services and introduce more clearly defined standards, particularly in areas such as digitalization, data management, and service quality. At the same time, it may also be considered that the provisions introduced in relation to pricing, technical obligations, and operational processes could give rise to varying implications for different market participants.

On the other hand, it may be expected that the practical reflections of these provisions and their impact on the sector will become clearer through secondary regulations and implementation practices to be introduced by the Board. In this context, it is anticipated that the effects of the relevant amendments will take shape over time, and we continue to closely monitor the evolution of the process.

 @Zeynep EMİROĞLU