In unlicensed generation, inverter kWh does not mean the investor is paid for those kWh. In some cases the regulation treats the energy as if the incumbent supplier produced it: the market operator and the incumbent pay nothing; the record goes to YEKDEM as an unpaid contribution. The plant keeps running. The invoice line stops. Our unlicensed-solar compliance guide splits subscriber-group and transfer issues. This article looks at operational recording mistakes and the cash shock.
150 thousand kWh
1 MW example
Assumed monthly output
586 thousand TL
Commercial
VAT included, illustrative
5.86 mn TL
10 MW scale
Same unit × 10
0 TL
Severe outcome
That period’s generation fee
Why 586 thousand TL is serious
The example is a 1 MW unlicensed plant producing 150,000 kWh in a month and that month’s output being booked as unpaid. A rough commercial (ticarethane) active-energy equivalent including VAT is about 586,000 TL. The same assumption at 10 MW is 1.5 million kWh and about 5.86 million TL. This is not an EMRA tariff decision. The unit, band, subscriber group and VAT rate change by month. The point is scale: a loan instalment, an EPC balance or cash flow can vanish in one billing period.
| Plant | Monthly output (assumption) | Unpaid-record equivalent |
|---|---|---|
| 1 MW | 150,000 kWh | ≈ 586,000 TL |
| 5 MW | 750,000 kWh | ≈ 2.93 million TL |
| 10 MW | 1,500,000 kWh | ≈ 5.86 million TL |
1. The contract-power floor (LUY 28/5 and 28/6)
The sum of contract powers in the associated consumption connection agreements cannot fall below the floor the regulation sets for that plant. The floor changes with invitation-letter vintage (after or before 12 May 2019), whether the plant is Article 5/1(h) plus municipality / industry / irrigation, and whether installed capacity or the application contract power is smaller. In our contract-power glossary entry the unit is kW, not kWh. If the floor breaks, that period’s output can be booked to unpaid YEKDEM.
- After 12 May 2019, 5/1(h) “other person”: the floor is usually installed capacity.
- 5/1(h) + municipality / industry / irrigation: a 2× build right exists; the floor is often the application contract power and rises to installed capacity if load exceeds the plant.
- Before 12 May 2019: the floor is usually min(installed capacity, application contract power).
2. When the consumption site changes (LUY 28/7)
Ending the link or moving it to another load without the network operator and incumbent supplier knowing can book that period as unpaid. Even with notice the new site must still carry the 28/5 or 28/6 floor. If a wind/solar application won on the 14/6-b consumption criterion, the new sites’ annual kWh cannot be below the application consumption. “The factory closed, we linked the warehouse” is not enough on its own.
3. No load, line dead at acceptance, theft
- If associated load has no electricity that month except force majeure (28/9), output can be booked unpaid.
- If associated sites were not consuming at acceptance (28/10), the same risk lasts until they start.
- After theft at an associated point (28/8), a proportional share may be unpaid that month and the next six billing periods.
4. Subscriber group, 2× cap, single supplier, storage
If associated loads after 12 May 2019 are not in the same subscriber group (30/6), that period’s output may be unpaid — detail in our unlicensed-solar compliance guide. In Hourly Netting 2026 and our unlicensed solar sales guide the 2× cap (26/17) applies except to households: the excess can still be netted; surplus after netting is unpaid. If several eligible consumers do not take from one supplier (23/5, 30/5), netting may not close. Export from integrated storage (Add. Art. 3) is not paid; if the share cannot be split, all surplus may go unpaid.
| Question | Why it is read | Cash at risk |
|---|---|---|
| Invitation-letter date? | 28/5 or 28/6 | Period output |
| Which Article 5 limb? | 2× right, closed ç/d sales | Surplus or whole period |
| Σ contract ≥ floor? | 28/5–28/7 | Period output |
| Same subscriber group? | 30/6 | Period output |
| Annual 2× cap? | 26/17 (except households) | Surplus above the cap |
| Single supplier? | 23/5, 30/5 | Netting + sales |
| Acceptance / SUA signed? | 18/3, 19/4 | Test / delay kWh |
Why advice and monitoring sit together
The regulation is public. Application lives in the plant file. Saying “this month goes unpaid” without reading the invitation letter, connection agreement, Article 5 limb, YEPDİS / LÜM row and billing period together is wrong. The opposite is also wrong: changing the load link, contract power or supplier without reading the text. That is why our industrial energy-management pages keep the portfolio on one screen; the decision is still taken with an expert.
Close
Unpaid YEKDEM is the “we generated but it could not be sold” record. In a month, a 1 MW plant can lose hundreds of thousands of lira; 10 MW can lose millions. The text sits on EMRA’s unlicensed-generation page. Your ruling sits in the invitation letter, acceptance and associated load. The right order: have the file read, watch the floor and the group, close changes with the network and the supplier on the same day. The statute and the regulation stay here; the plant’s dates are read separately.