Aggregator License Conditions In The Electricity Market
The license to be obtained for the market activity carried out by the aggregator within the framework of combining the generation and/or consumption of one or more network users allows companies to operate on a legal basis.
In the Turkish electricity market, aggregation activities can be carried out by legal entities holding an aggregator license to be obtained from the Energy Market Regulatory Authority (EMRA) within the framework of the Electricity Market Law No. 6446, the Regulation on Aggregation Activities in the Electricity Market and the relevant legislation, or by legal entities holding a supply license, provided that it is included in the license.
In addition, according to the Electricity Market Licensing Regulation published in the Official Gazette dated 2/11/2013 and numbered 28809 in the Official Gazette dated 2/11/2013, in the second paragraph of Article 6 of the Regulation on Aggregation Activities in the Electricity Market, the conditions that legal entities must meet in the license application, which can be granted for at least ten and at most forty-nine years, taking into account the nature of the activity, can be listed as follows.
a. Company Establishment and Structure
Establishment in accordance with the Turkish Commercial Code: Only companies established as a joint stock company or limited liability company can obtain an aggregator license.
Subject of Activity Compatibility: There must be a provision in the articles of the association of the applicant legal entity stating that aggregation activities can be carried out.
Minimum Capital Condition: The company must meet the minimum capital requirements set by EMRA. As of 2025, these limits are set as 28,000,000 TL for a supply license and 50,000,000 TL for a aggregation license.
Resident Requirement in Turkey: The company headquarters must be located within the borders of Turkey.
The Condition of Shareholding: If the legal entity is a joint stock company, its articles of association must include a provision stating that all its shares, except for those traded on the stock exchange in accordance with the capital markets legislation, are registered shares and that the company cannot issue bearer share certificates except for those to be issued for trading on the stock exchange.
b. License Revocation Restriction
Shareholders, chairman and members of the board of directors, managers in limited companies, and those who have resigned from office within one year prior to the license cancellation date, who directly or indirectly hold 10% or more shares in a legal entity whose license has been canceled, for three years following the license cancellation.
- Cannot obtain a new license or apply for a license,
- Cannot hold direct or indirect shares in a legal entity applying for a license,
- They cannot take part in boards of directors or similar positions.
c. License and Guarantee Fees
In order to obtain an aggregator license, in addition to all these, the license and guarantee fees determined by EMRA must be paid. In 2025, the license fee for the aggregator license to be applied in 2025 was determined as TL 10,000,000, the license amendment fee as TL 73,450 and the license duplication fee as TL 15,280. In addition, the annual license fee to be paid in 2026 for the aggregation activity in 2025 was determined as 0.015 kurus per kWh sold within the scope of aggregation activity, excluding sales related to licensed and unlicensed generation facilities in the portfolio.
d. Technical and Financial Competence
In addition, in order to obtain a license.
- Having the necessary infrastructure (such as data management, forecasting and monitoring systems),
- Documentation of operational capacity to provide uninterrupted service in the energy supply chain,
- Being registered in the trade or industry registry,
- Being liable for income or corporate tax,
- Establishing a corporate structure to prevent conflicts of interest that may arise between the Company's aggregation activities and other market activities that may be incompatible
technical and financial qualifications must also be completed.
Finally, the information and documents that legal entities that will apply for a license must submit to EMRA within the scope of the application are set out in the List of Information and Documents to be Submitted in the License Application in Annex-4 of the Procedures and Principles Regarding Applications for Pre-License and License Transactions.
Accordingly, the information and documents to be submitted for Aggregator License applications are as follows:
- License Application Petition
- Authorization Certificate
- Articles of Association
- Shareholding Structure Documents
- Control Statement/Document
- Documents Showing the Current Capital Amount of the Legal Entity
- License Fee
- Declaration of Non-Banning
For further information and support, please contact us at info@lbfpartners.com
LBF Partners Law Firm
In the Turkish electricity market, aggregation activities can be carried out by legal entities holding an aggregator license to be obtained from the Energy Market Regulatory Authority (EMRA) within the framework of the Electricity Market Law No. 6446, the Regulation on Aggregation Activities in the Electricity Market and the relevant legislation, or by legal entities holding a supply license, provided that it is included in the license.
In addition, according to the Electricity Market Licensing Regulation published in the Official Gazette dated 2/11/2013 and numbered 28809 in the Official Gazette dated 2/11/2013, in the second paragraph of Article 6 of the Regulation on Aggregation Activities in the Electricity Market, the conditions that legal entities must meet in the license application, which can be granted for at least ten and at most forty-nine years, taking into account the nature of the activity, can be listed as follows.
a. Company Establishment and Structure
Establishment in accordance with the Turkish Commercial Code: Only companies established as a joint stock company or limited liability company can obtain an aggregator license.
Subject of Activity Compatibility: There must be a provision in the articles of the association of the applicant legal entity stating that aggregation activities can be carried out.
Minimum Capital Condition: The company must meet the minimum capital requirements set by EMRA. As of 2025, these limits are set as 28,000,000 TL for a supply license and 50,000,000 TL for a aggregation license.
Resident Requirement in Turkey: The company headquarters must be located within the borders of Turkey.
The Condition of Shareholding: If the legal entity is a joint stock company, its articles of association must include a provision stating that all its shares, except for those traded on the stock exchange in accordance with the capital markets legislation, are registered shares and that the company cannot issue bearer share certificates except for those to be issued for trading on the stock exchange.
b. License Revocation Restriction
Shareholders, chairman and members of the board of directors, managers in limited companies, and those who have resigned from office within one year prior to the license cancellation date, who directly or indirectly hold 10% or more shares in a legal entity whose license has been canceled, for three years following the license cancellation.
- Cannot obtain a new license or apply for a license,
- Cannot hold direct or indirect shares in a legal entity applying for a license,
- They cannot take part in boards of directors or similar positions.
c. License and Guarantee Fees
In order to obtain an aggregator license, in addition to all these, the license and guarantee fees determined by EMRA must be paid. In 2025, the license fee for the aggregator license to be applied in 2025 was determined as TL 10,000,000, the license amendment fee as TL 73,450 and the license duplication fee as TL 15,280. In addition, the annual license fee to be paid in 2026 for the aggregation activity in 2025 was determined as 0.015 kurus per kWh sold within the scope of aggregation activity, excluding sales related to licensed and unlicensed generation facilities in the portfolio.
d. Technical and Financial Competence
In addition, in order to obtain a license.
- Having the necessary infrastructure (such as data management, forecasting and monitoring systems),
- Documentation of operational capacity to provide uninterrupted service in the energy supply chain,
- Being registered in the trade or industry registry,
- Being liable for income or corporate tax,
- Establishing a corporate structure to prevent conflicts of interest that may arise between the Company's aggregation activities and other market activities that may be incompatible
technical and financial qualifications must also be completed.
Finally, the information and documents that legal entities that will apply for a license must submit to EMRA within the scope of the application are set out in the List of Information and Documents to be Submitted in the License Application in Annex-4 of the Procedures and Principles Regarding Applications for Pre-License and License Transactions.
Accordingly, the information and documents to be submitted for Aggregator License applications are as follows:
- License Application Petition
- Authorization Certificate
- Articles of Association
- Shareholding Structure Documents
- Control Statement/Document
- Documents Showing the Current Capital Amount of the Legal Entity
- License Fee
- Declaration of Non-Banning
For further information and support, please contact us at info@lbfpartners.com
LBF Partners Law Firm
b.erkilic@lbfpartners.com