Despite the Club’s repeated advice about environmental-violation fines in Turkish waters, several vessels were penalized in 2025 with individual fines reaching a million dollars. The pollution fines in Turkiye will be increased by 25.49 % based on the inflation adjustment announced by the Directorate of Revenue Administration on 03 November 2025.

Taking the cases recently handled by the Club as examples, the environmental administrative penalties imposed on entered ships in Turkiye display the following common features:

1. Timing – just before sailing and with the authorities fully prepared
   Officials usually inform the ship without warning that it is suspected of illegal discharge, presenting photographs, video or other evidence already in their possession. Investigators immediately take samples alongside, board, and begin questioning, leaving the crew with little time to react.

2. Complex procedure for release of ships
   The competent Turkish authorities normally require the full amount to be paid, or a LOU issued by the P&I Club, before the vessel is allowed to sail. All relevant documents must be translated into Turkish and notarized, and payment must be made in Turkish Lira. Because of currency restrictions, the payment will be subject to delay and exchange rate volatility, regardless of direct or third-party payment, increasing the total cost.

3. Risk of PSC detention
   A pollution allegation often triggers a PSC inspection; if deficiencies (e.g. in the ballast-water system) are found, the ship may be detained even after the pollution fine has been settled.

4. Appeals are difficult
   Owners are entitled to lodge an appeal to any fines before an administrative court within 30 days of the fine’s notification date. However, appealing the fine does not affect the obligation to pay and if an objection is lodged, the 25 % reduction for payment within 30 days will not apply. Turkish authorities collect evidence (samples, statements, test results) very quickly, so appeals on the ground of “lack of evidence” generally have a low probability of success.

5. Criminal exposure for crew
   Under Turkish criminal law environmental pollution is a criminal offence. Once a file is opened, the prosecutor launches an investigation and individual crew members may be named suspects, exposing them to detention, indictment and even imprisonment. Although lawyers report no actual arrests for pollution offences so far, the risk cannot be ignored.

6. Heavy losses for owners
   Apart from the fine itself, the process – from the notification and retention of the Master’s certificate, through sampling and repeated investigations to the final penalty decision – can last several days, causing severe delays. If the incident is not accepted as an “accidental discharge”, payment of the fine will be on the owners.

In view of above, the pollution fines will be applied from 01.01.2026 to 31.12.2026. For more information on the revised 2026 Tariff and recommendations, read Correspondent Vitsan circular here.

For more information, please contact Managers of the Association.

Attachments:

File	File size
Vitsan Circular.pdf	242 kB
LP242025 Pollution Fines in Turkiye for 2026.pdf	305 kB