EIA process in Turkey, a practical guide for foreign investors

If you are planning a factory, an energy project or a recycling plant in Turkey, the EIA process in Turkey (ÇED) will sit on your critical path long before the first concrete is poured. Nothing else, from the building licence to investment incentives, can be issued until the EIA decision is in hand. This guide explains where the EIA fits in a foreign investor's schedule, what changed in 2025 and 2026, and the mistakes we see most often.

Where the EIA sits in your Turkish project schedule

Foreign investors often plan the EIA as a permit to collect after the design is fixed. In Turkey it works the other way round. Article 6 of the EIA Regulation of 29 July 2022 states that no incentive, approval, permit, building licence or occupancy licence may be issued for a listed project without a positive EIA decision, and that the investment cannot be started or tendered before then.

A typical sequence for a greenfield manufacturing plant looks like this.

1. Site selection and land due diligence, including zoning status and EIA annex screening
2. Land purchase or lease, often conditional on a positive EIA outcome
3. EIA screening (Annex II) or full EIA (Annex I)
4. Investment incentive certificate application, where relevant
5. Zoning plan changes, building licence and construction
6. Temporary activity certificate and environmental permit before or at start-up

The EIA is therefore the gate between land and construction. If your board approves an EPC contract with a construction start date, that date should depend on the EIA decision, not the other way round.

Screen the site before you sign for the land

Two plots a few kilometres apart can lead to very different EIA routes. The annex your project falls under depends on capacity, but the difficulty of the process depends on the site. Forest land, coastal strips, drinking water basin protection zones, wetlands, archaeological sites and nature protection areas all bring extra consultations, extra studies and sometimes an outright refusal.

A short pre-acquisition screening answers three questions. Which annex applies, given your planned and future capacity? Which institutions will the commission consult, given the site's location? Are there constraints that would require seasonal surveys and so add months to the timetable? This costs little compared with a land deal, and it is the stage where a Turkey-based consultant saves foreign investors the most money.

The 2025 and 2026 changes that matter to investors

The EIA rules changed twice in quick succession. The changes that affect investors most are summarised below.

Applications filed before 5 March 2026 continue under the rules in force on the filing date where that is more favourable, according to Circular 2026/4. Older decisions issued as ÇED Gerekli Değildir remain valid.

Realistic timelines for planning

Statutory review periods in the regulation are short, often 5 to 15 working days for each step. The overall timeline is driven by the time needed to prepare good files, to complete surveys and to answer the commission. These are the ranges we use for planning.

The EIA report for an Annex I project must be submitted within one year of the project-specific format, with one extension of up to 180 calendar days. If spring flora surveys or bird migration counts are needed, plan backwards from the right season, not from the date the format is issued.

Common mistakes foreign investors make

1. Starting site works early. Clearing land, building access roads or placing foundations before the decision counts as starting the investment. The authority can stop the works immediately and the file becomes much harder to defend.
2. Applying for today's capacity only. A second line added three years later is assessed on the total capacity, and can push the plant into Annex I. If expansion is likely, include it in the first file.
3. Treating the commitment letter as a formality. Every commitment in the EIA report or Project Introduction File becomes an enforceable obligation. Engineers should check stack heights, water sources and treatment methods before the letter is signed.
4. Not planning for the public meeting. Since March 2026 the owner or an authorised representative must attend. A foreign director without a Turkish power of attorney cannot simply send a local employee.
5. Assuming the Turkish EIA satisfies the lenders. Banks applying IFC Performance Standards or EBRD requirements will ask for a gap analysis and supplementary studies. Planning both from the start avoids duplicate surveys.
6. Letting the decision lapse. A ÇED Olumlu decision expires if the investment has not started within five years. Delayed projects should track this date.

EIA, incentives and financing

Many foreign investors apply for an investment incentive certificate from the Ministry of Industry and Technology to obtain VAT and customs duty exemptions and other support. Because Article 6 of the EIA Regulation lists incentives among the approvals that cannot be issued without an EIA decision, the EIA timetable directly affects the incentive timetable. In practice the two files are prepared in parallel and the incentive is finalised once the decision is available.

Lenders follow the same logic. A development bank or Equator Principles bank will typically make the EIA decision a condition precedent to first disbursement, and will review the EIA report as part of its own environmental and social due diligence.

Running the process from abroad

Everything in the Turkish EIA happens in Turkish, through the Ministry's online system, letters to the applicant and meetings in Ankara or the province where the project sits. Foreign investors usually work through a Turkish subsidiary or project company, appoint a local representative by notarised power of attorney, and rely on their consultant for day-to-day contact with the authorities.

What you should expect from your consultant is English reporting that lets you make decisions without reading Turkish letters: a status update at an agreed interval, translated summaries of each commission comment with the proposed answer, an English executive summary of the report, and a list of every commitment the decision creates. You should also expect the consultant to say plainly which certified institution holds the competence certificate and signs the file.

After the decision

A ÇED Olumlu decision opens the way to the building licence and construction, but it is not the last environmental step. Plants listed in the Environmental Permit and Licence Regulation need a temporary activity certificate at start-up and a five-year environmental permit, and large installations now also need an SYD certificate under the Industrial Emissions Management Regulation in force since 1 December 2025. Full Annex I projects must also submit progress reports during construction.

For the detailed process, statutory periods and what we deliver, see our environmental impact assessment in Turkey service. The permit stage is covered on our environmental permits in Turkey page, and lender requirements on our environmental and social due diligence page. The current regulation text is available from the Official Gazette and the Ministry's EIA directorate.