On this page
- What CSRD reporting requires after Omnibus I
- CSRD timeline and thresholds as of October 2026
- The revised ESRS in practice
- CSRD data from Turkish subsidiaries of EU groups
- Non-EU groups with large EU turnover
- Suppliers asked for VSME data
- How a CSRD project runs with us
- What we need from you
- Cost and timeline drivers for CSRD work
- What you receive
What CSRD reporting requires after Omnibus I
CSRD reporting is the disclosure regime set by Directive (EU) 2022/2464. In-scope companies publish a sustainability statement in their management report, prepared under the European Sustainability Reporting Standards (ESRS), based on a double materiality assessment and checked by an independent assurance provider at limited assurance level.
We support three types of client from our offices in Turkey. EU groups with Turkish subsidiaries need reliable subsidiary data for the consolidated statement. Turkish and other non-EU groups with large EU sales need to prepare for their own reporting from financial year 2028. Turkish suppliers need to answer EU customers who ask for VSME or ESRS-style data.
CSRD timeline and thresholds as of October 2026
The Stop-the-clock Directive (EU) 2025/794 delayed the second and third waves by two years. The Omnibus I Directive (EU) 2026/470, published on 26 February 2026, then rewrote the scope. Member States must transpose it by 19 March 2027.
| Company type | Test | First financial year | Report published |
|---|---|---|---|
| First-wave companies still above the new thresholds | Previously large public-interest entities with more than 500 employees | FY2024 (already reporting) | Since 2025 |
| First-wave companies below the new thresholds | Member State option to exempt them | May be exempt for FY2025 and FY2026, out of scope from FY2027 | Depends on national law |
| Large EU companies and groups | More than 1,000 employees and more than EUR 450 million net turnover | FY2027 | 2028 |
| Listed SMEs | Removed from mandatory scope | Not applicable | Voluntary only |
| Non-EU parent groups | More than EUR 450 million EU net turnover in each of the last two years, plus an EU subsidiary or branch above EUR 200 million | FY2028 | 2029 |
| Value chain companies with up to 1,000 employees | Not in scope. Protected by the value chain cap | Cap applies from FY2027 | Not applicable |
National transposition is uneven, so the exact first-year position depends on where your EU reporting entity sits. We check the law in the relevant Member State before fixing the reporting plan.
The revised ESRS in practice
The revised standards were adopted by the Commission on 3 July 2026 and published as Delegated Regulation (EU) 2026/1563 on 21 September 2026. They are mandatory for financial years beginning on or after 1 January 2027. For financial year 2026, companies may apply the 2023 ESRS, the 2023 ESRS with selected reliefs from the new act, or the revised ESRS in full, and must say which one they used.
EFRAG's technical advice removed around 61% of mandatory datapoints. The changes that matter most for groups with Turkish operations are these.
- A top-down approach to the double materiality assessment is allowed, using reasonable and supportable information available without undue cost or effort.
- Value chain metrics may cover an objectively defined part of the value chain rather than every supplier.
- Anticipated financial effects under ESRS E1 get longer phase-ins, two years for qualitative and four years for quantitative information for new reporters.
- Binding sector-specific standards have been dropped. The Commission will issue non-binding sector guidance instead.
ESRS E1 on climate change remains the most data-heavy standard. It asks for the transition plan, Scope 1, 2 and 3 emissions, energy consumption and mix, and climate targets. Turkish plants are often the most energy-intensive part of an EU group, so their data quality affects the whole statement.
CSRD data from Turkish subsidiaries of EU groups
A Turkish subsidiary is not an EU undertaking, so the CSRD does not apply to it directly. Its figures still appear in the parent's consolidated sustainability statement, and the auditor will test them. The same problems come up again and again.
- Workforce definitions. Turkish payroll and SGK categories do not map one to one to ESRS S1. Subcontracted workers (taşeron) must be treated as non-employees, and their numbers often sit outside HR.
- Market-based Scope 2. Renewable electricity claims in Turkey rely on YEK-G guarantees of origin issued through EPİAŞ or on I-REC certificates. Without the certificates and cancellation records, the auditor will fall back on the grid factor.
- Pollution and water. Measurement reports under Turkish emission and discharge permits use different units and frequencies from the group template.
- Evidence in Turkish. Invoices, permits and accident reports are in Turkish, and group auditors need someone who can read and translate the relevant parts.
We prepare a subsidiary data pack in the group's template, with source evidence, conversion notes and a short English methodology memo for the group team and its auditor.
Non-EU groups with large EU turnover
A Turkish group that sells more than EUR 450 million a year in the EU, and has an EU subsidiary or branch above EUR 200 million net turnover, will have to publish a group-level sustainability report from financial year 2028. The report is published in 2029 through the EU subsidiary or branch.
The separate standards for third-country groups are still being drafted by EFRAG and had not been adopted by the Commission as of October 2026. Groups can still prepare now. The turnover test looks back over two years, so 2026 and 2027 figures already matter. The data needed (greenhouse gas emissions, workforce, business conduct) is the same as under the ESRS and largely the same as under TSRS.
Suppliers asked for VSME data
The Commission published the VSME as Recommendation (EU) 2025/1710 in July 2025. Omnibus I then turned it into the basis of a voluntary standard, adopted as Delegated Regulation (EU) 2026/1560 and in force since 24 September 2026.
From financial year 2027, a CSRD reporter cannot require more than the datapoints in Annex II of that standard from a value chain company with 1,000 employees or fewer, and contract clauses that demand more are ineffective. This protects most Turkish suppliers from long bespoke questionnaires. The cap does not cover data requested under other laws, such as CBAM. We explain the details in our article on what suppliers must report after the CSRD Omnibus.
How a CSRD project runs with us
- Scope check against Directive (EU) 2026/470 and the transposing law, including group structure, subsidiary exemptions and the reporting year (1 to 2 weeks).
- Gap analysis of existing reports, ISO 14064-1 inventories, policies and data systems against the revised ESRS (2 to 3 weeks).
- Double materiality assessment with stakeholder input and documented scoring (4 to 8 weeks).
- Data collection design and the first data round across EU and Turkish sites (6 to 10 weeks).
- Drafting of the sustainability statement sections and the ESRS index (4 to 6 weeks).
- Pre-assurance review and support during the auditor's limited assurance work (3 to 6 weeks).
Subsidiary data packs and VSME responses are much shorter projects, usually four to eight weeks depending on the number of sites.
What we need from you
- Group structure chart and the consolidation scope used in the financial statements
- Average headcount and net turnover for the last two financial years, split between EU and non-EU entities
- The group's ESRS data template, KPI definitions and reporting calendar, if the parent already reports
- Site list with activities, permits and production volumes for Turkish entities
- Energy, fuel, water and waste records by site, plus SGK, payroll and OHS data
- Policies, codes of conduct and any existing GRI, CDP or EcoVadis submissions
Cost and timeline drivers for CSRD work
A full ESRS statement for a group is a different project from a subsidiary data pack or a VSME response, so we quote after a scoping call. The main drivers are the number of legal entities and sites, the number of material topics, how deep the Scope 3 inventory has to go and how mature the existing data systems are.
The auditor's calendar also matters. Data for a December year-end usually has to be closed by February or March, so the materiality assessment and the data templates should be finished in the third quarter of the reporting year. Groups that start in the final quarter tend to rely heavily on estimates in the first year.
What you receive
- A written scope opinion with the applicable first reporting year
- Double materiality assessment report with the impact, risk and opportunity register
- Data collection templates, KPI definitions and calculation files
- Draft sustainability statement sections in English, with Turkish working versions where needed
- Evidence file and methodology notes prepared for the assurance provider
Ekol Çevre does not provide assurance. We prepare you for it and coordinate with your auditor. For the wider picture, see our ESG reporting services, and for groups that also report in Turkey, our TSRS and ISSB reporting service.