---
title: "The 19 October package: new rules for unlicensed solar, YEKDEM, imbalance and storage"
url: https://frekansenerji.com/en/insights/epdk-october-2026-regulation-package/
lang: en
description: "On 19 and 21 October EPDK amended eight regulations and issued seven board decisions: remote curtailment of unlicensed solar, KGÜP discipline in YEKDEM, a V value of 100 TL/MWh, new KÜPST coefficients and MW-based collateral for storage. We review the package from an investor’s perspective."
datePublished: 2026-10-21
dateModified: 2026-10-21
---

# The 19 October package: new rules for unlicensed solar, YEKDEM, imbalance and storage

On 19 and 21 October EPDK amended eight regulations and issued seven board decisions: remote curtailment of unlicensed solar, KGÜP discipline in YEKDEM, a V value of 100 TL/MWh, new KÜPST coefficients and MW-based collateral for storage. We review the package from an investor’s perspective.

Regulation

29 min read · October 21, 2026

## Eight regulations, seven decisions

The Official Gazette of 19 October 2026 carried eight EPDK regulation amendments together with seven Board decisions dated 24 September; two more changes to collateral rules followed on 21 October. Most of the texts are the final versions of drafts EPDK put out for consultation in June 2026.

The common thread is clear: managing the midday solar surplus and preparing the balancing market for a 15-minute structure. Unlicensed plants become direct addressees of emergency instructions for the first time, compliance with the final daily generation programme (KGÜP) is now measured in money for YEKDEM plants, and the capital and collateral burden on storage gets lighter.

8 regulations

Amended on 19 October; 7 Board decisions the same day

100 TL/MWh

V value from November 2026; previously 150

900 kW

Minimum plant size for emergency instructions to unlicensed plants

30 April 2027

Date to which SCADA integration and remote switching penalties for unlicensed plants are deferred

Table 1 The package at a glance

| Text | Main change | In force |
| --- | --- | --- |
| Unlicensed Electricity Generation Regulation | Remote control; no payment for output that ignores instructions; no capacity limit for integrated storage | 19 October 2026 |
| Balancing and Settlement Regulation (DUY) | Emergency instructions to unlicensed plants; KGÜP for every settlement unit (UEVÇB); settlement periods in the DGP; instructions verified by metering | 19 October 2026; thermal rule 1 January 2027 |
| YEK Certification and Support Regulation | Output above the expected level (KGÜP − YAT + YAL) in hours with a YAT instruction or below V in surplus does not count for YEKDEM if the PTF is below the YEK price | 19 October 2026 |
| Licensing Regulation and Board Decision 14912 | Storage capital and collateral in MWe instead of MWh; collateral held until a hybrid plant is complete | 19 October 2026 |
| Storage and Connection regulations | Contract capacity cap lifted for consumer storage; distribution collateral at most 1 times for users with a clean payment record | 19 October 2026 |
| Ancillary Services Regulation | Proportional deductions in demand-side participation; testing transition to 31 December 2026 | 19 October 2026 |
| OIZ Regulation | Load-shedding and data-sharing obligations for organised industrial zones | 19 October 2026 |
| Board Decisions 14907 and 14911 | New KÜPST formula and coefficients; KÜPST for suppliers’ consumption units; V = 100 TL/MWh | November 2026 billing period; consumption units 1 January 2027 |
| DUY and Board Decision 14954 (21 October) | Bilateral and futures trading ban for participants that fail to top up collateral | 21 October 2026 |

## Remote curtailment for unlicensed solar

At the heart of the package is the midday surplus. The Grid Code made unlicensed plants a party to emergency measures in December 2025; the October package builds the mechanism. The system operator’s emergency load-shedding instruction goes to the regional incumbent supplier and to aggregators, and the distribution company or OIZ applies it to the unlicensed plant.

Under the new paragraph in article 75 of the DUY, the incumbent supplier creates a single settlement unit (UEVÇB) for the unlicensed plants in its region. Instructions are applied among plants of 900 kW or more in installed electrical capacity, starting with the largest and moving down; the text sets no order for plants below 900 kW. Among plants of equal electrical capacity, those with higher mechanical capacity, then earlier first acceptance, then an earlier connection agreement come first. The order starts with the incumbent supplier’s portfolio, and the incumbent supplier sends the list of plants in scope to the distribution company or OIZ. The distribution company or a distribution-licensed OIZ can switch a plant off remotely and must notify the producer by phone and durable medium within 15 minutes after the emergency ends. Re-energising the plant is the producer’s responsibility. Aggregators build their own remote control systems for their portfolios.

Under new paragraphs in the OIZ Regulation, distribution-licensed organised industrial zones must apply these instructions and pass data on unlicensed plants and compliance to the incumbent supplier. OIZs must also follow TEİAŞ’s instructions under the emergency measures of the Grid Code and report the data it requests completely and on time; an OIZ that does not comply faces the sanctions in article 16 of Electricity Market Law no. 6446.

Sanctions have two layers. No payment is made for the output corresponding to the part of the instruction that was not followed; the amount is recovered from the producer and deducted from the total cost of YEKDEM. Penalty clauses added to the connection agreement by decision 14909 target plants that fail to install SCADA or cannot be switched remotely because of a fault. For producers that do not apply for the revision within 60 days, the Board-approved agreement provisions in force apply; not applying is no way around the new terms.

Table 2 New sanctions for unlicensed plants

| Situation | Sanction | From |
| --- | --- | --- |
| Emergency instruction not followed | No payment for the part not followed; amount recovered from the producer | 19 October 2026 |
| SCADA integration not provided | One times the monthly system use fee for each month | After 30 April 2027 |
| Remote switching impossible because of a SCADA or communication fault | One times the monthly system use fee per breach; at most three times a month | After 30 April 2027 |
| Faulty SCADA equipment not repaired within one month of a warning | 1% of that month’s system use fee for each day the breach continues | 19 October 2026 |
| Revision of the connection agreement | Plants in scope apply within 60 days; the Board-approved terms in force apply to those that do not | By 18 December 2026 |

How the unpaid amount is calculated varies widely with the plant’s support status. For a solar plant within its ten-year support period the reference is the price in the YEK Law schedule: 13.3 US cents/kWh for plants commissioned before 2021. For plants past their support period the price in Presidential Decision 11415 applies: 90% of the YEKDEM price, capped at the hourly PTF. For plants paid for excess generation at their consumer group tariff, the tariff price of that group and tier applies. Since the PTF is usually close to zero in emergency hours, the real deterrent for these plants is the penalty clauses that apply after April 2027.

The unlicensed regulation also makes two netting adjustments. Payment for excess generation is now explicitly tied to the volume left after the market operator’s hourly netting. Where generation and consumption are not in the same distribution region and the associated consumption is connected to transmission, own consumption will be billed at the single-rate retail energy tariff for transmission users.

## KGÜP discipline in YEKDEM

For licensed plants in YEKDEM the most important change is in article 23 of the regulation. The rule applies in two situations: in settlement periods when the plant receives a down-regulation (YAT) instruction in an emergency or in the balancing market, and in periods when the PTF or SMF is below V and the system is in surplus. In these periods expected net generation is taken as the plant’s KGÜP minus YAT, plus up-regulation (YAL) instructions, the net imbalance caused by secondary frequency control and the reserve provided in limited frequency sensitivity mode. Output above that does not count as YEKDEM generation if the PTF is below the YEK price plus any local content bonus. A part of an instruction reported as not delivered during reconciliation is not deducted; the full instruction counts.

In hours when the PTF falls below V this condition is met in practice every time. A plant that does not submit a KGÜP is treated as having a KGÜP of zero, so all its output in that hour falls outside YEKDEM. The rule is stricter for local content payments: for plants commissioned after 30 June 2021 that receive the local content bonus without being registered in YEKDEM, and for the local content payment on capacity increases under article 6/C, output above the expected level in these periods is not counted, whatever the PTF. A similar rule that applied only on public holidays other than Sundays was repealed and replaced by this general rule for every day.

> Generating above KGÜP in surplus hours is no longer paid by YEKDEM.

The imbalance side points the same way in those hours. Under the DUY, when the lower of PTF and SMF is below V, a positive imbalance creates a charge of B rather than revenue. In spring middays when the PTF drops to zero, the right strategy for a YEKDEM wind or solar plant is now clear: submit a realistic KGÜP and manage the surplus with a YAT bid or by curtailing output.

The other changes to the YEKDEM regulation are more technical. In hybrid plants with storage, energy under YEKDEM is tracked with virtual records capped at the capacity in operation; once capacity is full, newly stored energy reduces existing records proportionally. For a plant that joins YEKDEM later, energy held in storage when it joins is not paid by YEKDEM even if it is discharged afterwards. Plants commissioned after 30 June 2021 that are not registered in YEKDEM and use local components receive the local content bonus as a YEK payment. If misleading or forged documents on the support conditions are found in the pre-licence, licence or acceptance process, the plant is removed from that year’s final YEK list and the sanctions in article 16 of Law 6446 also apply. Repayment is no longer output times the YEK price but the YEK payments actually made, each updated from its payment date at the rate in article 51 of Law 6183. Periods with a negative YEK payment, when the plant paid into YEKDEM, count as zero, so the plant cannot deduct those payments from the repayment. If the Ministry finds that a component does not qualify for the local content bonus, the bonus paid for it is also recovered, updated at the same rate.

## Imbalance: V from 150 to 100

In the imbalance formula in force since 1 January 2026, V is a threshold for low-price hours. A shortfall is priced at no less than V. For surplus generation, if the lower of PTF and SMF is below V, output earns nothing and instead creates a charge of B per MWh, i.e. 100 TL/MWh plus the coefficient. Decision 14911 lowers V from 150 to 100 TL/MWh from the billing period after its publication, that is from November 2026.

`Shortfall: EDT− = EDM− × max(V, PTF, SMFn) × (1 + k)` `Surplus: if min(PTF, SMFp) < V EDT+ = −EDM+ × B × (1 + l)` `otherwise EDT+ = EDM+ × min(PTF, SMFp) × (1 − l)`

V floor and trigger value; 100 TL/MWh from November 2026 B charge on surplus generation; 100 TL/MWh k, l 3% or 6% depending on system direction SMFn, SMFp the hour’s SMF; with a 15-minute DGP, the highest and lowest of the quarters

Table 3 Effect of the change in V: 2 MWh deviation

| Case | V = 150 TL/MWh | V = 100 TL/MWh |
| --- | --- | --- |
| Surplus; PTF and SMF 120 TL/MWh | −212 TL (B charge) | +225.6 TL (revenue) |
| Shortfall; PTF and SMF 0 | 309 TL payable | 206 TL payable |
| Surplus; PTF and SMF 0 | −212 TL (B charge) | −212 TL (unchanged) |

Illustrative calculation. The system is assumed to be in surplus in all three cases: l = 6% for surplus generation, k = 3% for a shortfall; B = 100 TL/MWh. The special rule at the price cap is not shown.

The effect cuts both ways. In hours when the PTF is between 100 and 150 TL/MWh, surplus generation moves from a charge back to revenue; the floor price for a shortfall falls by a third. In hours when the PTF drops to zero nothing changes. The 19 October DUY amendment also books imbalance receivables and payables gross per settlement period rather than net per month: the net amount stays the same, but the payable side grows.

## KÜPST: wider scope

The charge for deviation from the final daily generation programme (KÜPST) prices a plant’s deviation from its KGÜP beyond a tolerance. Decision 14907 leaves the tolerance for wind and solar unchanged at 15% and 8%; these values have applied since 1 January 2026. The big jump happened then; today’s change is in the formula and the scope.

Figure 1 KÜPST tolerance coefficient for wind and solar

![Frekans Enerji](/_ds/frekans-design-system-4d9ac81c-c3eb-4c27-a344-ef6c4ece4cc2/assets/logos/frekans-full-blue.svg)

Wind Solar

Aug 2020

10%

10%

Feb 2023

21%

12%

Jan 2025

17%

10%

Jan 2026

15%

8%

Nov 2026

15%

8%

Tolerance as a percentage of planned generation, by effective date. Source: EPDK Board Decisions 9422, 11589-2, 13025, 14029 and 14907.

`UDÜPS = |(UEVM − UEÇM) − BUDÜP|` `KÜPSM = UDÜPS − m × BUDÜP (if UDÜPS > m × BUDÜP; otherwise 0)` `KÜPST = KÜPSM × max(PTF, SMF) × n`

BUDÜP expected generation: KUDÜP + YAL − YAT + secondary and limited frequency reserve adjustments UEVM metered injection; UEÇM metered withdrawal (MWh) m tolerance coefficient; n price coefficient

The deviation is now calculated on a net basis: injection minus withdrawal, compared with the net plan. This stops charging and own consumption from looking like deviations at hybrid and storage plants. Distribution-connected unlicensed plants (through the incumbent supplier’s or the aggregator’s settlement unit) and standalone storage come into scope for the first time; consumption units follow from 1 January 2027.

Table 4 KÜPST coefficients from November 2026

| Unit | Tolerance (m) | Price coefficient (n) |
| --- | --- | --- |
| Wind | 15% | 0.05; 0.08 with 30 or more outage entries a month |
| Solar | 8% | 0.05; 0.08 with 30 or more outage entries a month |
| Hybrid generation with storage | 5% | 0.10 |
| Other sources | 5% | 0.05; 0.08 with 25 or more outage entries a month |
| Transmission-connected unlicensed, per plant | 20% | 0.02 |
| Distribution-connected unlicensed, per participant (new) | 25% | 0.01 |
| Standalone storage (new) | 20% | 0.02 |
| Incumbent supplier consumption units (2027) | 75% | 0.01 |
| Other consumption units (2027) | 30% | 0.01 |

An example: a 10 MW wind farm that notifies 6.0 MWh for an hour and generates 4.5 MWh deviates by 1.5 MWh against a tolerance of 0.9 MWh. The 0.6 MWh above the tolerance, at a price of 3,000 TL/MWh and a coefficient of 0.05, creates a KÜPST of 90 TL. The same deviation cost 43.2 TL in 2025 with a 17% tolerance and a 0.03 coefficient. For wind and solar the cost roughly doubled at the start of this year; nothing changes that from November.

Illustrative calculation. max(PTF, SMF) = 3,000 TL/MWh, no instructions or reserve adjustments, fewer than 30 outage entries in the month.

## KÜPST for suppliers too

The least discussed consequence of the package concerns supply companies. With the 19 October DUY amendment, notifying a KGÜP and available capacity became an obligation for every settlement unit (UEVÇB), including consumption and storage, not just generation. A supplier with a consumer portfolio must notify, for each settlement unit, the next day’s consumption programme per settlement period by 15:30 every day; it can update the programme until half an hour after the intraday market closes. This obligation took effect on publication.

From 1 January 2027, decision 14907 also links deviations from this programme to KÜPST. The calculation mirrors generation: the gap between metered withdrawal and the notified programme, to the extent it exceeds the tolerance, is priced at max(PTF, SMF) × 0.01. The tolerance is 75% for the regulated portfolios of incumbent suppliers (non-eligible consumers and eligible consumers that have not chosen a supplier, for example) and 30% for all other consumption units, including eligible consumer portfolios. A supply licence holder that only trades and has no consumer portfolio has no consumption unit, so this charge does not arise.

Table 5 KÜPST in a supplier portfolio: one-hour example

| Case | Notified consumption | Actual | Tolerance (30%) | Above tolerance | KÜPST |
| --- | --- | --- | --- | --- | --- |
| Accurate forecast | 100 MWh | 110 MWh | 30 MWh | 0 | 0 TL |
| Deviation above tolerance | 100 MWh | 140 MWh | 30 MWh | 10 MWh | 300 TL |
| Night hour, low consumption | 20 MWh | 28 MWh | 6 MWh | 2 MWh | 60 TL |
| No programme notified | 0 MWh | 100 MWh | 0 MWh | 100 MWh | 3,000 TL |

Illustrative calculation. Eligible consumer portfolio (30% tolerance), max(PTF, SMF) = 3,000 TL/MWh, price coefficient 0.01. The last row assumes the plan is taken as zero in an hour with no programme notified; EPİAŞ’s 2027 settlements will confirm the practice.

The amount looks small: each MWh above the tolerance costs only 1% of its energy value. The real risk lies in two places. The first is low-consumption hours and portfolios with behind-the-meter solar: where consumption drops sharply at midday, a 30% tolerance is easily exceeded. The second is notification discipline: in an hour with no programme, the whole consumption counts as deviation, and participants that habitually fail to notify a KGÜP are also reported to EPDK for sanctions under article 16 of the Law.

## Balancing moves towards 15 minutes

In the DUY, references to the “hour” in the balancing power market (DGP) became “settlement period”. The DGP settlement period was defined as 15 minutes in 2025, with the proviso that it would not start before 1 January 2027. The October amendment completes the legal groundwork for this transition; imbalance settlement stays hourly.

The split has a cost. In the imbalance formula a shortfall is priced at the hour’s highest SMF and a surplus at its lowest. Once the SMF is split into four quarters, the gap between the two widens. With quarter-hour SMFs of 1,800, 2,400, 3,100 and 2,000 TL/MWh, a shortfall settles at 3,100 and a surplus at 1,800 TL/MWh; with a single hourly SMF the gap is much narrower.

Table 6 Changes in the DGP and instructions

| Topic | New rule | In force |
| --- | --- | --- |
| KGÜP and available capacity | All settlement units, including consumption and storage, notify, not just generation | 19 October 2026 |
| Verification of instructions | Delivered YAL and YAT volumes are determined from metered injection, withdrawal and KGÜP within the article 78 reconciliation | 19 October 2026 |
| Generation above KGÜP | A “run at KGÜP” warning instead of an instruction; reported to EPDK if ignored | 19 October 2026 |
| Report on instructions not delivered (14908) | If delivery is below 85% for reservoir hydro, 80% for gas and 70% for others | 19 October 2026 |
| Bid price spread (14910) | Excluding hydro, the gap between the highest and lowest bid in the same direction may not exceed 50% | 19 October 2026 |
| Cold and warm reserve | Such bids without an instruction are not taken into account for the SMF | 19 October 2026 |
| Intraday price limits | Lower limit is the day-ahead and balancing market floor (0 TL/MWh); upper limit is the price cap plus the smaller imbalance coefficient (3%): 4,500 × 1.03 = 4,635 TL/MWh | 19 October 2026 |
| Wind, solar, other exempt plants and aggregator groups | With TEİAŞ approval, may become balancing units for up- and/or down-regulation, so also in one direction only | 19 October 2026 |
| Thermal plants | Loading and unloading curves declared in the market system, updated at most four times a year; instructions to online units according to these curves | Declaration 19 October 2026; instructions 1 January 2027 |

For wind and solar the most interesting article is the option to become a balancing unit in one direction only, for example down-regulation. In surplus hours, instead of curtailment without an instruction or a B charge, output can be reduced through a YAT bid at a price the plant sets itself. Implementation depends on TEİAŞ’s assessment. Aggregators also get a registration rule: a plant can join an aggregator portfolio only after at least one unit has passed Ministry acceptance and its settlement unit records are complete on the transfer date.

## Storage: from MWh to MW

The clearest gain for storage investors is that capital and collateral are now calculated on power (MWe) rather than unit capacity (MWh). Under the Licensing Regulation and decision 14912, amounts for hybrid and standalone storage applications are based on power. For a four-hour battery the burden falls to roughly a quarter.

Table 7 Standalone storage capital and collateral: 100 MWe / 400 MWh

|  | MWh basis (old) | MWe basis (new) |
| --- | --- | --- |
| Additional capital requirement | 336 million TL | 84 million TL |
| Collateral | 21.42 million TL | 8.82 million TL |

Illustrative calculation, using the unit investment amount of 4,200,000 TL in decision 13134 and the supply or aggregator licence formulas: capital P × BYT × 0.20; collateral BYT × \[2.1 + (P − 100) × 0.01\].

In exchange, getting collateral back at hybrid plants becomes harder. The collateral submitted with the licence application is now returned only once the whole facility is in operation; even if the solar or wind part is commissioned, the collateral stays blocked until the storage is complete. For the storage units, the refund takes into account the power of the accepted storage unit; where storage is built smaller than licensed, the text does not make clear whether the difference is returned or forfeited. If the committed storage is not built within the licence period, the collateral is already forfeited except in cases such as force majeure. That makes a “build generation first, defer storage” approach more expensive.

An important cap has also gone for behind-the-meter storage. Consumers can now install batteries larger than their contracted capacity, provided they fit an automatic power control and cut-off system that prevents export to the grid and limits withdrawal to the contracted capacity. Storage integrated with unlicensed generation stays limited by electrical power but can be built without a capacity (MWh) limit. Standalone storage was brought under emergency instructions and given light KÜPST coefficients.

One provision that was in the June draft but not in the final text should also be noted: applying the fixed system use fee in one direction only for standalone and hybrid storage. It is absent from the published text; how the fixed fee applies to storage remains an open question.

## Licensing, collateral and demand response

A new paragraph in the Licensing Regulation matters for stalled projects. If an event the Board previously accepted as force majeure becomes permanent and prevents completion of the investment, it is no longer assessed under the force majeure article. For pre-licences and licences that have waited years on environmental permits, zoning or grid connection, the route to extensions narrows.

The Connection Regulation makes two procedural changes. A distribution-connected licensed plant cannot ask to leave the distribution system while its licence runs; to move to transmission it first amends the connection point in its licence. An applicant that chooses to build the required distribution grid itself signs the construction contract within 30 days of the connection agreement rather than at the same time.

Article 132/C of the DUY gets tougher for projects with land disputes. Where a pre-licence or licence holder fails to pay the compensation, costs or enforcement amount arising from lawsuits or enforcement proceedings brought against EPDK or the ministry handling the expropriation over project land, EPDK sets a payment deadline; after it, the company’s market receivables have been transferred to the Authority since 1 January 2026. Now, until the debt is paid, the company cannot notify bilateral contracts as a seller and its forward sale notifications are cancelled. It cannot join an aggregator portfolio or a balancing group; if it is in one, it is removed in the first billing period after the notice, and if it is the group’s responsible party, the group is dissolved. These receivables go to the Authority before any other use. For bilateral buyers and aggregators this is a new counterparty risk.

For suppliers the change cuts both ways. The maximum ratio used to set system use collateral with the distribution company falls to at most one times for users that have paid their system use bills in full over the past 24 months and have not defaulted on collateral; the distribution company must return the resulting excess by 19 November without waiting for a request. Collateral can now also be given as an electronic letter of guarantee. The rule is permanent too: excess collateral is returned within 10 working days on request, and a call for additional collateral gives 10 working days. The distribution company reports to EPDK any user whose collateral falls short of the required amount by 20% or more and who does not make up the gap. On the other hand, after the 21 October amendment a participant that fails to meet a collateral call at EPİAŞ can trade neither in the day-ahead and intraday markets nor in bilateral contracts and futures. The Licensing Regulation also widens a branding rule. Since April 2026 suppliers other than the incumbent supplier, and aggregators, could not use the distribution region’s name in their company name or the distribution company’s brand and logo, with a compliance deadline of 31 December 2026. Now any name, brand or logo that may suggest a link to the distribution company is also banned. The October amendment sets no separate transition period, and the text does not make clear whether the 31 December 2026 deadline also covers the wider scope.

Demand-side participation under the Ancillary Services Regulation was redesigned. The effect of hours rated “did not participate” is no longer confined to a single hour; the monthly capacity payment is cut by the share of those hours in total instructed hours. Curtailing more load than instructed now has its own scale: an excess of up to 50% of the instruction counts as delivered, while a larger excess counts as not delivered and no activation payment is made for that period. With TEİAŞ approval at least one hour before the activation instruction starts, an excess above 50% also counts as delivered. For shortfalls the thresholds are unchanged: up to 10% delivered, 10% to 25% not delivered, 25% or more did not participate. The capacity tender announcement must now also cover a document, to be approved by the distribution company, with the meter data and contracted capacity of distribution-connected consumption sites. Availability checks, allowed at most twice in the critical months for one hour each, now instruct load reduction in equal proportion rather than equal amounts. The date from which TEİAŞ itself runs ancillary service performance tests and issues the certificates moved from 1 September to 31 December 2026; until then tests can be run by non-accredited firms provided a TEİAŞ observer is present.

19 Oct 2026

Entry into force Most regulation amendments in force on publication.

1 Nov 2026

V and KÜPST V = 100 TL/MWh; new KÜPST formula and coefficients.

19 Nov 2026

Collateral refund Return of excess distribution system use collateral.

18 Dec 2026

Connection agreement End of the 60-day period for unlicensed producers to apply for revision.

31 Dec 2026

Ancillary service tests End of the non-accredited testing transition.

1 Jan 2027

Thermal and consumption Ramp-curve instructions for thermal plants; KÜPST for consumption units; earliest date for the 15-minute DGP.

30 Apr 2027

SCADA penalties Deferral of penalty clauses in the unlicensed connection agreement ends.

## For investors

The package gives a clear answer to who bears the cost of the midday surplus: whoever creates it and does not stick to the plan. For a YEKDEM plant the KGÜP is no longer a formality but part of revenue; for an unlicensed plant, SCADA and remote control are a penalised condition of the connection agreement. When valuing a solar plant, curtailed output in surplus hours, MWh that go unpaid and the B charge now belong in the model.

The picture is more positive for storage. MWe-based capital and collateral make long-duration batteries cheaper, the size limit behind the meter is gone and standalone storage gets light KÜPST coefficients. Every MWh taken in surplus hours and moved to the evening peak is the mirror image of output that turns into a charge in those same hours; the package widens that gap.

In summary

01 Distribution-connected unlicensed plants face remote curtailment in emergencies; instructions apply to plants of 900 kW or more, no payment is made for output that ignores them, and penalties for missing SCADA integration and failed remote switching apply after 30 April 2027.

02 For licensed YEKDEM plants, output above the expected level (KGÜP minus YAT plus YAL) in hours with a YAT instruction, or in surplus hours when the PTF or SMF is below V, does not count as YEKDEM generation if the PTF is below the YEK price; without a KGÜP the plan is taken as zero.

03 V falls from 150 to 100 TL/MWh from November 2026; in hours when the PTF is between 100 and 150 TL/MWh, surplus generation earns revenue again.

04 KÜPST tolerances for wind and solar are unchanged at 15% and 8%; deviations are calculated net, and distribution-connected unlicensed plants, standalone storage and, in 2027, suppliers’ consumption units come into scope.

05 Storage capital and collateral are calculated in MWe instead of MWh, cutting the burden for a four-hour battery to roughly a quarter, but collateral at a hybrid plant stays blocked until the whole facility is in operation.

At Frekans we are mapping the SCADA and remote control status of every unlicensed plant in our aggregation portfolio and sharing a plan with our investors to close the gaps before April 2027. At the plants we manage we submit KGÜP under the new rules for surplus hours, and for hybrid projects at the investment stage we are adding MWe-based collateral and the blocking period to the financing model.

## What takes effect when

Most of the regulation changes in the package took effect on publication. The monetary changes to imbalance and KÜPST start with the November 2026 billing period, and KÜPST for suppliers’ consumption units starts on 1 January 2027. The table below brings all the dates together.

Table 8 Effective dates

| Date | Change | Basis |
| --- | --- | --- |
| 19 October 2026 | Unlicensed generation: remote control by distribution companies and OIZs; no payment for output that ignores an instruction; no MWh cap on integrated storage | Unlicensed Generation Regulation amendment |
| 19 October 2026 | Balancing: emergency instructions to unlicensed plants; KGÜP and EAK for all settlement units; warning for output above KGÜP; intraday price limits; one-directional balancing units; declaration of thermal curves | DUY amendment, art. 27 |
| 19 October 2026 | Market participation: registration rule for aggregator portfolios; sales and portfolio ban for plants that do not pay expropriation debts | DUY arts. 32/C and 132/C |
| 19 October 2026 | YEKDEM: output above the expected level not counted in hours with a YAT instruction or below V in surplus; holiday rule repealed; virtual records for storage; repayment rule for forged documents | YEK Certification and Support Regulation amendment, art. 7 |
| 19 October 2026 | Licensing and storage: capital and collateral in MWe instead of MWh; collateral blocked for hybrid plants; force majeure that becomes permanent; wider branding rule | Licensing Regulation amendment; Board Decision 14912 |
| 19 October 2026 | Connection: distribution collateral at most 1 times for users with a clean payment record; 10 working day and 20% rules; consumer storage larger than contracted capacity | Connection and System Use and Storage regulations |
| 19 October 2026 | Proportional deduction and excess curtailment scale in demand response; instruction and data duties for OIZs | Ancillary Services and OIZ regulations |
| 19 October 2026 | Report on instructions not delivered; bid price spread limit; reactive power agreement | Board Decisions 14908, 14910 and 14913 |
| 21 October 2026 | A participant that fails a collateral call is barred from bilateral contracts and futures as well as the day-ahead and intraday markets; overdue debt becomes a reason to raise collateral | DUY art. 132/E amendment; Board Decision 14954 |
| 1 November 2026 | V falls from 150 to 100 TL/MWh | Board Decision 14911 |
| 1 November 2026 | New KÜPST formula (net deviation) and coefficients: generators, standalone storage, transmission- and distribution-connected unlicensed plants | Board Decision 14907, art. 7 |
| 19 November 2026 | Excess distribution collateral from the one-times rule returned without a request | Connection and System Use Regulation, provisional art. 15 |
| 18 December 2026 | Last day for unlicensed producers in scope to apply for revision of their connection agreements | Unlicensed Generation Regulation, provisional art. 14(1) |
| 31 December 2026 | TEİAŞ takes over ancillary service performance tests; until then non-accredited firms may test with a TEİAŞ observer | Ancillary Services Regulation, provisional art. 12 |
| 31 December 2026 | Compliance deadline for the name, brand and logo rule introduced in April 2026; unclear whether it covers the wider scope | Licensing Regulation, provisional art. 47 |
| 1 January 2027 | KÜPST for suppliers’ consumption units: tolerance 75% in the incumbent supplier’s regulated portfolios and 30% in other portfolios; price coefficient 0.01 | Board Decision 14907, provisional art. 1 |
| 1 January 2027 | Instructions to online thermal units according to their ramp curves | DUY provisional art. 41 |
| 1 January 2027 | Earliest date for 15-minute settlement in the balancing market; not changed by this package, and imbalance stays hourly | DUY provisional art. 40 (January 2025) |
| 30 April 2027 | Penalties for missing SCADA integration and failed remote switching start for unlicensed plants; the 1% daily penalty for unrepaired SCADA faults was not deferred | Unlicensed Generation Regulation, provisional art. 14(2); Board Decision 14909 |

In the board decisions, “the billing period following publication” means 1 November 2026, as a billing period is a calendar month. The imbalance coefficients did not change in this package: 6% in the direction of the system, 3% against it and 3% both ways when the system is balanced (Board Decision 14030, in force since 1 January 2026).

## Sources

-   [Official Gazette, 19 October 2026, no. 33405: amendments to the Unlicensed Electricity Generation, Balancing and Settlement, YEK Certification and Support, Licensing, Storage, Connection and System Use, Ancillary Services and OIZ regulations](https://www.resmigazete.gov.tr/eskiler/2026/10/20261019.htm)
-   [EPDK Board Decisions 14907–14913, 24 September 2026 (Official Gazette, 19 October 2026, no. 33405)](https://www.resmigazete.gov.tr/eskiler/2026/10/20261019-9.pdf)
-   [Amendment to the Electricity Market Balancing and Settlement Regulation (Official Gazette, 21 October 2026, no. 33407)](https://www.resmigazete.gov.tr/eskiler/2026/10/20261021-3.htm)
-   [EPDK Board Decision 14954, 15 October 2026: amendment to the Collateral Procedures and Principles (Official Gazette, 21 October 2026, no. 33407)](https://www.resmigazete.gov.tr/eskiler/2026/10/20261021-8.pdf)
-   [EPDK Board Decisions 9422 (2020), 11589-2 (2023), 13025 (2024) and 14029 (2025): KÜPSM and KÜPST coefficients](https://www.resmigazete.gov.tr/eskiler/2025/12/20251229-18.pdf)
-   [EPDK Board Decision 13134, 26 December 2024: capital and collateral requirements for pre-licence and licence applications (Official Gazette, 29 December 2024)](https://www.resmigazete.gov.tr/eskiler/2024/12/20241229-3.pdf)
-   [Amendment to the Electricity Market Balancing and Settlement Regulation (Official Gazette, 29 December 2025, no. 33122)](https://www.resmigazete.gov.tr/eskiler/2025/12/20251229-1.htm)
-   [EPDK, draft amendments to electricity market legislation, June 2026](https://www.epdk.gov.tr/Detay/Icerik/4-16379/elektrik-piyasasinda-cesitli-mevzuatlarda-degisik)

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