Turkey has no third licence type called a storage licence. An investor that commits to build storage receives a wind or solar generation pre-licence; the battery is part of that plant. A supplier or aggregator adds a standalone battery to its own licence by amendment. Revenue is written in three places: the day-ahead and intraday price spread, a smaller portfolio imbalance, and a capacity fee for primary or secondary frequency control once the plant is on the transmission system at 30 MW or more. The same megawatt-hour cannot be written to all three.
None
Separate storage licence
Amendment or generation licence
2 MW
Build threshold
Supply or aggregator
30 MW
Primary / secondary
Transmission connection
No
Both on one unit
PFC and SFC together are closed
How licensing works: two doors
Article 7/10 of Law No. 6446 gives a wind and/or solar generation pre-licence, up to the storage capacity the applicant commits to build. Article 7/11 lets an operating wind or solar licence add capacity up to the storage power, without leaving the site and without instantaneous injection above the licensed power. That door is a generation licence. It is not pure battery trading; energy delivered to the grid passes through the storage unit. The second door is Article 7 of the Storage Activities Regulation: a standalone facility tied to neither generation nor consumption, connected directly to the grid.
| Investor | Supplier / aggregator | |
|---|---|---|
| Licence | Generation pre-licence / licence | Existing supply or aggregator licence |
| Plant | Wind or solar plus a storage commitment | Standalone, direct grid connection |
| Procedure | Pre-licence | A separate licence amendment per facility |
| Floor | Generation up to the storage power | 2 MW |
| Settlement | Unit linked to the generation plant | The participant’s injection and withdrawal |
Filing order: the first application goes to EPDK
EPDK issues the pre-licence, the licence and the amendment. Under Article 15/2 of the Licence Regulation, EPDK asks for the connection opinion: TEİAŞ at transmission level, and the distribution company of the plant’s region at distribution level. The opinion reaches EPDK within 45 days of the request and is then notified to the applicant. Acceptance or objection takes 10 business days; silence counts as acceptance. EPİAŞ is the market operator. Day-ahead (GÖP), intraday (GİP) and settlement sit with EPİAŞ after the licence is in force and the meter has entered settlement. The plain steps are in the licensed storage roadmap.
| Institution | Role | When |
|---|---|---|
| EPDK | Pre-licence, licence, amendment | First filing |
| TEİAŞ | Transmission connection opinion; later the connection and system-use agreements. Ancillary-service tests | EPDK requests the opinion |
| Distribution company | Connection opinion and agreements at distribution level | EPDK requests the opinion |
| EIA (ÇED) | Environmental decision | After the Board finds the file suitable |
| EPİAŞ | Market registration, GÖP, GİP, settlement | After acceptance and metering |
| Step | Where | What happens |
|---|---|---|
| 1 | EPDK | If there is no supply or aggregator licence yet, that licence comes first. Storage is not a separate licence. |
| 2 | EPDK | A separate amendment per facility (Art. 24/19). Capital is the minimum plus 20 percent of the investment. Collateral follows the Board rate. |
| 3 | TEİAŞ or the distribution company | EPDK requests the opinion. Transmission is TEİAŞ; distribution is the regional company. A new supply application that includes storage also needs a TEİAŞ technical opinion. Primary or secondary capacity fees need a transmission connection and at least 30 MW. |
| 4 | EIA, then EPDK | Once the Board approves, the EIA application is filed within 45 days of notification. When the decision reaches EPDK in time, the amendment is endorsed on the licence. |
| 5 | TEİAŞ or the distribution company | Connection agreement and system-use agreement. The layout follows Annex EK-3. Then construction and provisional acceptance. |
| 6 | EPİAŞ | Injection and withdrawal enter the existing participant’s settlement. GÖP and GİP bids are placed here. Ancillary-service qualification is a TEİAŞ test. |
| Step | Where | What happens |
|---|---|---|
| 1 | EPDK | Law Art. 7/10: a wind and/or solar pre-licence up to the storage the applicant commits to build. On an operating plant, Art. 7/11 is a capacity-increase amendment. |
| 2 | TEİAŞ | EPDK sends the file for a connection opinion in the order it was taken into evaluation (Art. 15/9). TEİAŞ gives opinions until the regional capacity is full. The first file past that remainder is asked to revise down to it. TEİAŞ also reviews the storage unit’s technical suitability. |
| 3 | EPDK, then the General Directorate of Energy Affairs | The opinion is notified; 10 business days to accept or object. A positive opinion is published, and third parties have 10 business days to object on personal rights only. The file then goes to technical review in the same order. Whether EPDK is accepting new 7/10 files depends on that period’s announcement. |
| 4 | Grid operator | Construction, generation licence, acceptance. Energy reaches the grid through the storage unit. The plant stays inside the site. |
| 5 | EPİAŞ | Producer registration, GÖP, GİP and settlement come after acceptance. Ancillary services open with a TEİAŞ test when the plant is on the transmission system at 30 MW or more. |
The supplier and the aggregator add the battery to their own licence
A supply or aggregator licence holder may build one or more standalone facilities under the same licence, provided each is at least 2 MW. Charge is withdrawal and discharge is injection in the settlement quantities. Article 24/19 of the Electricity Market Licence Regulation does not treat this as a new licence: the facility is endorsed onto the licence by amendment. Each facility needs its own amendment application and its own amendment fee. Article 34/A expressly lets an aggregator build this plant to balance its portfolio. If aggregation is already endorsed on a supply licence, the same right arrives by amendment, without a second licence.
- Capital: the supply or aggregator minimum, plus 20 percent of the total investment amount estimated by the Authority.
- Collateral at the rate set by Board decision for the capacity.
- Connection and system use under Licence Regulation Article 15/2, plus the EIA decision.
- A TEİAŞ technical opinion when storage is added to a new supply application.
- Injection in a settlement period cannot exceed what the accepted electrical capacity can deliver. The excess is a free contribution to YEKDEM.
Primary and secondary pay; hot reserve is not a separate product
What the market calls primary reserve is primary frequency-control reserve in the regulation. Secondary reserve is secondary frequency-control reserve. The 17 December 2024 amendment opened both to standalone storage. The payment is a capacity fee for the megawatts you keep available that hour. Energy surplus or deficit during the service is not a second premium; it settles as imbalance. TEİAŞ asks primary response to deliver half the reserve within 15 seconds and all of it within 30 seconds at a 200 mHz deviation, and to hold that power for at least 15 minutes. Response delay must not exceed 2 seconds. The hourly ratio of energy capacity to reserve capacity is at least 1.25 for primary and 2.25 for secondary. Secondary also requires AGC, a response within 30 seconds, and a ramp of at least 1.5 percent of installed power per second.
| Spoken name | Official product | Threshold | Revenue |
|---|---|---|---|
| Primary reserve | Primary frequency-control reserve | Transmission, 30 MW | Capacity fee (TL/MW) |
| Secondary reserve | Secondary frequency-control reserve | Transmission, 30 MW, AGC | Capacity fee (TL/MW) |
| Hot reserve | No separate tender | Balancing unit | Up / down balancing instruction |
| Black start | System restoration | If TEİAŞ assigns the path | Assignment agreement |
How day-ahead, intraday and the portfolio balance on one battery
A supplier’s position is hourly: portfolio withdrawal, bilateral contracts, the day-ahead match (GÖP), the intraday correction (GİP), and the residual imbalance. A standalone battery is another leg of that position. A day-ahead purchase in a cheap hour increases withdrawal as charge. Discharge in an expensive hour is injection, or it replaces that hour’s expensive purchase. When the forecast error becomes clear during the day, the intraday market corrects the day-ahead plan. The battery moves before the gap is closed at the system marginal price. For an aggregator the same leg is portfolio balance: when generation and consumption programmes diverge, storage covers the gap with energy that is not locked to an ancillary service.
| Window | Price | Battery | Position |
|---|---|---|---|
| 03–06 | Low market price | Charge | GÖP buy, withdrawal rises |
| 12–15 | High market price | Discharge | GÖP sell, or injection instead of an expensive buy |
| Intraday error | GİP | Remaining energy | Forecast error shrinks |
| Primary or secondary hour | Capacity fee | Reserve lock | That MWh is not written to arbitrage |
- Round-trip loss and network charges eat the price spread before any profit is written.
- Energy kept available for primary or secondary is deducted from that hour’s GÖP offer.
- The injection cap is the accepted electrical capacity.
- An incumbent supplier may also add a facility on its supply licence. Cross-subsidy between the regulated activity and commercial storage is prohibited.
Arbitrage is open on licensed standalone storage
On unlicensed integrated storage, buy-low and sell-high to the grid is closed; energy delivered to the grid can count as a free contribution. On a licensed standalone facility, purchases and sales are written into settlement, so the spread is open. The limit is physics and commitment, not a legal ban: efficiency, connection capacity, collateral, and the split of the same megawatt-hour between reserve and trade. A 2 MW plant runs that spread on GÖP and GİP. Transmission and 30 MW also open a capacity-fee door; once that door opens, the energy left for arbitrage shrinks.
ENOPTIMAL holds this decision in one optimisation
On the market desk, the hourly price, the portfolio forecast and the GÖP/GİP position already sit together. A licensed battery is the third constraint on that desk. For each hour the optimisation solves charge or discharge, day-ahead or intraday, how many megawatts are locked for primary or secondary, and whether the remainder covers the portfolio error. The same megawatt-hour is not written into two offers. A reserve commitment is not hidden inside the arbitrage profit. The 2 MW floor and the 30 MW floor stay apart: a small plant is spread and balance, a large transmission plant is a capacity-fee candidate.
- The hourly market price and the portfolio forecast stay in the same decision.
- Charge is withdrawal and discharge is injection on the settlement position.
- A primary or secondary lock is deducted from that hour’s saleable energy.
- The intraday error is closed with the remaining energy, without breaking the locked reserve.
Conclusion
The licence path is an amendment to the supply or aggregator licence, not a separate storage certificate. The revenue path is writing one megawatt-hour to the right hour and the right product: a GÖP charge in the cheap hour, discharge in the expensive hour, GİP on the error, and only one of primary or secondary on a 30 MW transmission plant. The ENOPTIMAL market desk holds these constraints in the same optimisation. Book a demo from the contact form.