Turkey’s Nuclear Regulatory Agency Has Tightened the Procedures for Modifying Equipment and Operating Procedures at Nuclear Facilities

On October 2, 2026, the Official Gazette of Turkey (Resmî Gazete) published amendments by the Turkish Nuclear Regulatory Authority (Nükleer Düzenleme Kurumu, “NDK”) to the Regulation on Licensing Activities for Nuclear Facilities[1] (“Licensing Regulation”) and the Regulation on the Management System for Nuclear Facilities, Radiation Facilities, and Radioactive Waste Management Facilities[2] (“Management System Regulation”). Most of the amendments took effect on the date of publication. The new procedure for making changes at nuclear facilities (Article 41 of the Regulations on Licensing Activities) will take effect on January 2, 2027.

The amendments apply to organizations that carry out activities related to nuclear facilities based on NDK licensing documents (approvals, permits, and licenses). With regard to the Akkuyu NPP, the licensee is Akkuyu Nükleer A.Ş. Organizations within the Rosatom State Corporation that participate in the project as designers, equipment manufacturers, contractors, and service providers are indirectly affected by the amendments through the licensee’s processes and the terms of supply contracts.

Categories of Changes and the Procedure for Making Them

The amendments apply to any changes to the designs, systems, and equipment of a nuclear facility (including documentation and software), operating limits and conditions, operating procedures, organizational structure, programs, and management systems. Effective January 2, 2027, the licensee is required to classify each change into one of three categories based on its significance to safety (Article 41 of the Licensing Regulations) prior to implementing it:

• Category 1 – changes that could significantly affect safety or that require a change to the design basis or the conditions of the licensing document (e.g., the list of design basis accidents, operating limits and conditions). These may be made only with the approval of the NDK;

• Category 2 – changes that require updating the safety analysis report or other documents submitted to the NDK but do not significantly affect safety and do not alter the conditions of the licensing document. The licensee must notify the NDK of such changes no later than 20 business days in advance. The NDK may classify such a change as Category 1, in which case authorization must be obtained;

• Category 3 – changes that do not affect safety, including changes to equipment that is not safety-critical. These are reflected in a list of changes that the licensee submits to the NDK within the timeframes established by the NDK.

Implementing changes falling under Categories 1 or 2 without the regulator’s authorization or notification constitutes a violation of Article 41 of the Regulations on Licensing Activities. For violations of the law or the terms of the licensing document regarding a nuclear power plant, the NDK has the right to impose an administrative fine on the licensee pursuant to subparagraph “c” of Part 1 of Article 25 of Turkish Law No. 7381 “On Nuclear Regulation.” In 2026, the fine ranges from 1,748,231 to 17,437,657 Turkish lira[3]. If the violation is not rectified within the specified time limit, the fine is doubled each time. If the violation poses a safety threat, the NDK also has the right to restrict, suspend, or revoke the license[4] .

For contractors and suppliers, the risk is primarily related to timelines: the start of work for which personnel and equipment have already been mobilized may be postponed until a permit is obtained, and a change— for which a notification has been issued—may be reclassified as Category 1. Costs associated with downtime and the remobilization of resources are allocated in accordance with the terms of the contract.

Conclusions of Designers and Manufacturers Regarding Changes

According to the new version of Article 18(5) of the Management System Regulations, as a general rule, prior to approving a change, the licensee shall seek the opinion of the organizations that designed, manufactured, or constructed the affected structures, systems, and equipment in their pre-change condition. The subject of the opinion is the impact of the planned change on the design principles and functions of these structures, systems, and equipment. The opinion does not replace the licensee’s decision: the licensee approves the change, while the designer or manufacturer expresses their opinion. The opinion is included in the licensee’s documentation regarding the assessment of the change. For Category 1 and 2 changes, the assessment information is attached to the application for a permit or to the notification submitted to the NDK. For Category 3 changes, only a list is submitted to the NDK, while the documents are retained by the licensee and made available to the NDK for inspection.

Article 19 of the Management System Regulations requires that configuration management for nuclear power plants be conducted using a computerized system. The receipt of opinions pursuant to Article 18(5) and the implementation of configuration management using a computerized system must be ensured by January 2, 2027 (transitional provision of Article 2 of the Management System Regulations).

Physical Nuclear Security and Cybersecurity Plans

Effective October 2, 2026, an application to the NDK for a construction permit (inşaat izni) for a nuclear facility must be accompanied by a physical nuclear safety plan (nükleer emniyet planı) and a cybersecurity plan (siber güvenlik planı) (Article 24 of the Licensing Regulations). The current versions of these plans must also be attached to applications for a commissioning permit and an operating license (Articles 25 and 26). At reactor facilities, fuel loading into the reactor is permitted only after the implementation of the security measures specified in the plan for the four zones has begun: the restricted access zone, the secured zone, the internal zone, and the critical zone[5]. Furthermore, nuclear materials may not be brought onto the site until the relevant structures, systems, and equipment have been commissioned and the implementation of the plan’s measures has begun.

If organizations within the Rosatom State Corporation have remote access to the plant’s systems (for example, for equipment diagnostics), such access must be reflected in the licensee’s cybersecurity plan and comply with it. It is advisable to agree on the procedure for granting such access and the conditions for modifying it before submitting the plan to the NDK or before its next update.

The new requirements regarding the composition of documents do not apply to all applications (başvuru). If, by the date the amendments take effect, a decision on a submitted application has not been made, the rules in effect on the date of its submission shall apply. This is established by a transitional provision—Temporary Article (geçici madde) 2 of the Licensing Regulations. Therefore, the applicable requirements must be determined separately for each power unit at the Akkuyu NPP.

Requirements for Supplies to Nuclear Facilities

The amendments (Articles 6(7), 14, 15, and 21 of the Licensing Regulations) also establish requirements for services and products supplied to nuclear facilities. These requirements apply to equipment manufacturers and organizations that perform testing, inspection, and calibration. These manufacturers and organizations include entities of the Rosatom State Corporation. These requirements take effect on October 2, 2026.

Measurements, analysis, testing, inspection, calibration, and similar work within the scope of activities regulated by the NDK must be performed by accredited organizations: Turkish organizations must be accredited by the Turkish Accreditation Agency (Türk Akreditasyon Kurumu, “TÜRKAK”); foreign organizations—accredited by a national accreditation body covered by international mutual recognition agreements involving TÜRKAK. It is also permissible to engage individuals certified in the relevant field, provided that the NDK deems them suitable. The NDK reserves the right to establish additional conditions.

TÜRKAK and the Federal Accreditation Service (Rosaccreditation) are participants in the International Laboratory Accreditation Cooperation’s Mutual Recognition Arrangement ( , ILAC MRA)[6]. Rosaccreditation’s scope of recognition includes testing and calibration laboratories and inspection bodies. Therefore, in our assessment, the accreditation of Russian laboratories in these areas meets the requirements of the regulation, unless the NDK establishes additional conditions.

Safety-critical equipment may be manufactured only with an NDK manufacturing permit (imalat izni). Upon receiving such a permit, the licensee may not begin manufacturing the equipment, its semi-finished products, or components until the NDK notifies the licensee of the established control points (kontrol noktaları)—that is, the stages of manufacturing the equipment, its semi-finished products, and components at which the progress and quality of work are verified. The licensee must also notify the NDK of the start of manufacturing for components and semi-finished products.

If a safety-critical component is procured as a finished product not specifically intended for nuclear facilities (hazır ürün), the licensee must verify its compliance with requirements prior to procurement. The licensee must notify the NDK of the measures to be taken for such verification and their schedule no later than 10 business days in advance so that the NDK can monitor them.

Recommendations

In light of the foregoing, we recommend that organizations involved in the construction of the Akkuyu NPP:

• review the Akkuyu project contracts regarding the allocation of risks related to regulatory delays, downtime, and changes in the scope of work, and agree with the licensee on who will classify the changes and prepare the documents for the NDK;

• approve the form of the conclusion regarding the impact of changes on the design basis and functions of structures, systems, and equipment (Article 18(5) of the Management System Regulations), designate the persons authorized to sign it, specify the language of the document, and establish the procedure for disclosing information, taking into account confidentiality and export control requirements;

• determine how remote access by State Corporation entities is reflected in the licensee’s cybersecurity plan;

• verify whether the testing and calibration laboratories engaged have been accredited by TÜRKAK or by a body that is a party to a mutual recognition agreement with TÜRKAK (for Russian laboratories—by Rosaccreditation under the ILAC MRA), and also include in the contract delivery schedules time for receiving control points from the NDK and deadlines for notifying the NDK of the start of manufacturing of components and semi-finished products and of the inspection of finished products (no later than 10 business days);

• determine the rules (taking into account the transitional provision of Article 2 of the Licensing Regulations) governing the review of applications for each power unit.

If necessary, we would be happy to assist in the implementation of any relevant projects.