Maritimeadmin

Subject: Marine Pollution Fines – Expected Increases for 2027

The relevant fixed monetary fines under Article 20 of Environmental Law No. 2872 are increased annually under Article 17(7) of Misdemeanours Law No. 5326, using the revaluation rate determined under Repeated Article 298(B) of Tax Procedure Law No. 213 and announced by a Tax Procedure Law General Communiqué. The Ministry of Environment, Urbanisation and Climate Change publishes the updated fine amounts. For the previous update, the respective communiqués—No. 585 and No. 2026/1—were published on 27 November 2025 and 30 December 2025, respectively.

The estimates below apply the 27.83% twelve-month average increase in TurkStat’s October 2026 Domestic Producer Price Index to the 2026 amounts, pending publication of the annual revaluation rate in the Official Gazette and confirmation of the official 2027 amounts in the environmental fines communiqué.


  1. ESTIMATED FINE AMOUNTS FOR 2027
  • Petroleum and Petroleum Products Discharged by Tankers
A For vessels of up to 1,000 GT TRY 7,353.22 per GT
Corporate (3x): TRY 22,059.66
B For vessels over 1,000 GT and up to 5,000 GT TRY 1,838.36 to be added per GT over 1,000 gross ton to the item A
Corporate (3x): TRY 5,515.08
C For vessels over 5,000 GT TRY 183.75 to be added per GT over 5,000 gross ton to the item A+B
Corporate (3x): TRY 551.25

  • Dirty Ballast Discharged by Tankers
A For vessels of up to 1,000 GT TRY 1,339.70 per GT
Corporate (3x): TRY 4,019.10
B For vessels over 1,000 GT and up to 5,000 GT TRY 267.27 to be added per GT over 1,000 gross ton to the item A
Corporate (3x): TRY 801.81
C For vessels over 5,000 GT TRY 42.41 to be added per GT over 5,000 gross ton to the item A+B
Corporate (3x): TRY 127.23

  • Petroleum Derivatives or Dirty Ballast Discharged by Ships and Other Marine Craft
A For vessels of up to 1,000 GT TRY 3,676.60 per GT
Corporate (3x): TRY 11,029.80
B For vessels over 1,000 GT and up to 5,000 GT TRY 735.34 to be added per GT over 1,000 gross ton to the item A
Corporate (3x): TRY 2,206.02
C For vessels over 5,000 GT TRY 183.75 to be added per GT over 5,000 gross ton to the item A+B
Corporate (3x): TRY 551.25

  • Domestic Wastewater, Specified Washwaters and Solid Waste Discharged by Tankers, Ships and Other Marine Craft

For vessels of up to 150 GT, fixed amounts apply:

1 For vessels up to 18 GT TRY 40,775
Corporate (3x): TRY 122,325
2 For vessels over 18 GT and up to 50 GT TRY 81,558
Corporate (3x): TRY 244,674
3 For vessels over 50 GT and up to 100 GT TRY 163,117
Corporate (3x): TRY 489,351
4 For vessels over 100 GT and up to 150 GT TRY 244,680
Corporate (3x): TRY 734,040

For vessels over 150 GT:

A For vessels over 150 GT and up to 1,000 GT TRY 1,838.36 per GT
Corporate (3x): TRY 5,515.08
B For vessels over 1,000 GT and up to 5,000 GT TRY 367.70 to be added per GT over 1,000 gross ton to the item A
Corporate (3x): TRY 1,103.10
C For vessels over 5,000 GT TRY 42.41 to be added per GT over 5,000 gross ton to the item A+B
Corporate (3x): TRY 127.23

The “Corporate (3x)” lines show the amount multiplied by three for institutions, organisations and enterprises (Environmental Law, Article 20)


  • Use of Marine Fuel Exceeding Applicable Sulphur Limits
A For vessels of up to 1,000 GT TRY 1,631.21 per GT
B For vessels over 1,000 GT and up to 5,000 GT TRY 203.88 to be added per GT over 1,000 gross ton to the item A
C For vessels over 5,000 GT TRY 40.79 to be added per GT over 5,000 gross ton to the item A+B

  1. KEY POINTS
  1. Protected Areas: Article 20 fines are doubled within officially designated Special Environmental Protection Areas. Marine and coastal examples include the Marmara Sea and Islands, Saros Bay, Karaburun–Ildır Bay, Foça, Datça–Bozburun, Gökova, Fethiye–Göcek, Köyceğiz–Dalyan, Patara, Kaş–Kekova, Finike Undersea Mountains, Belek and Göksu Delta. The Marmara designation under Decision No. 4758 of 4 November 2021 was amended by Decision No. 8948 of 6 September 2024. Check the applicable boundary maps.
  2. Corporate Multiplier: Under Article 20(2), fines under Article 20(1)(ı)(1)–(4) are tripled for institutions, organisations and enterprises. This multiplier excludes the sulphur fines under (hh) and shore-facility fines under (ğğ); protected-area and repeat-infringement adjustments may still apply.
  3. Repeat Infringements: Under Article 23, repetition within three years of the original act increases the relevant fine by 100% for the first repetition and 200% for subsequent repetitions, resulting in twofold and threefold fines, respectively.
  4. Hazardous Discharges: Under Article 20(ı), discharges of hazardous substances or hazardous waste attract ten times the fine calculated under the petroleum/petroleum-derivatives category applicable to the vessel.
  5. Payment Discount: Article 17(6) of Misdemeanours Law No. 5326 provides a 25% discount for payment within the applicable payment period: one month from notification unless a specific statutory period applies.
  6. Wastewater and Washwaters: Following the 2022 amendment, Article 20(ı)(4) covers domestic wastewater, detergent-containing water, foam, scrubber washwater, similar washwaters and solid waste.
  7. Tonnage Cap: The vessel-discharge fines in Tables I–IV are calculated using a maximum of 100,000 GT. This cap does not apply to the separate sulphur tariff under Article 20(hh).
  8. Own Clean-up: Under Article 20(ı), the fine is applied at one third where the vessel is established to have removed the pollution it caused using its own means after the incident.
  9. Payment or Security: Under Article 20(ı), vessels and other movable marine craft are prohibited from sailing and operating unless the fine is paid immediately in a single payment or adequate security is provided. Bank guarantees and guarantees from the vessel’s club insurer are recognised; confirm adequacy with the competent authority.
  10. Shore Facilities: Estimated 2027 base fines under Article 20(ğğ) are TRY 203,896 for management’s failure to notify the authorities of pollution within its management area, and TRY 203,896–815,603 for failure to take required marine-litter, waste and wastewater collection and management measures. One third applies to fishing shelters; other statutory adjustments may apply.
  11. Judicial Challenge: Under Articles 24–25, fine challenges must be brought against the Ministry before the competent administrative court within 30 days of notification. Filing does not automatically suspend collection. Payment does not waive the right to challenge within that period.

  1. OUR RECOMMENDATIONS

Implement these precautions under the Master’s and Chief Engineer’s supervision, following the vessel’s Safety Management System and applicable requirements while preserving essential cooling, safety and emergency systems, safe drainage and emergency readiness.

  1. Control deck drainage and use suitable scupper precautions during operations presenting a pollution risk.
  2. Secure routes capable of unauthorised pollutant discharge; record closures, seals and seal changes under vessel procedures.
  3. Use designated wastewater collection, treatment and holding arrangements, as applicable; monitor tank levels and capacity to prevent overflow and unauthorised discharge.
  4. Prevent pollutants, washwater, paint residues and garbage from entering the water during deck washing, painting and waste handling; observe local restrictions.
  5. Check compliance with applicable fuel sulphur limits and retain relevant fuel, sampling and changeover records, as applicable.
  6. Brief the crew, assign responsibilities and maintain relevant records. Confirm local requirements with the agent and promptly consult the P&I correspondent or legal advisers if pollution is alleged.