On this page
- What ESG reporting covers
- Who must report under which framework in 2026
- Double materiality and materiality assessment
- ESG data collection and KPIs
- ESG report drafting and structure
- Assurance readiness
- Supplier ESG questionnaires such as CDP and EcoVadis
- How an ESG reporting project runs
- What we need from you
- Cost and timeline drivers
- Why a Turkey-based ESG reporting team helps
What ESG reporting covers
ESG reporting is the structured disclosure of a company's environmental, social and governance impacts, risks and performance against a recognised standard. The main ones are the ESRS under the EU CSRD, IFRS S1 and S2 (adopted in Turkey as TSRS), the GRI Standards and the VSME. A report combines policies, targets and measured KPIs, and is increasingly subject to external assurance.
Ekol Çevre provides ESG reporting services from Turkey to three kinds of client. The first group must publish a sustainability statement by law. The second group is Turkish subsidiaries and suppliers that feed data into a parent's or a customer's report. The third group is exporters answering buyer questionnaires such as CDP and EcoVadis. We run the materiality assessment, set up data collection, calculate the KPIs, draft the report and prepare it for assurance.
Who must report under which framework in 2026
The rules changed twice in 2025 and 2026. The EU cut the scope of the CSRD sharply, and Turkey raised its TSRS thresholds and extended transition reliefs. The table shows the position as of October 2026.
| Framework | Who is in scope | First reporting year | Status in October 2026 |
|---|---|---|---|
| CSRD with ESRS (EU companies) | Companies with more than 1,000 employees and more than EUR 450 million net turnover (both tests) | Wave 1 since FY2024. Others from FY2027, published in 2028 | Omnibus I Directive (EU) 2026/470 in force since March 2026, transposition due by 19 March 2027 |
| CSRD for non-EU groups | Non-EU parent with more than EUR 450 million EU net turnover in each of the last two years and an EU subsidiary or branch above EUR 200 million | FY2028, published in 2029 | Separate standards for non-EU groups still being drafted by EFRAG |
| TSRS 1 and TSRS 2 (Turkey) | Listed companies, issuers, insurers and other listed categories above two of three thresholds (TRY 1 billion assets, TRY 2 billion revenue, 500 employees) for two consecutive years. Banks regardless of size | Periods beginning on or after 1 January 2024 | Thresholds raised in January 2026. Transition reliefs extended to 2026 reports in October 2026 |
| IFRS S1 and S2 (ISSB) | Set by each jurisdiction that adopts them | Effective from 1 January 2024 where adopted | Amendments to the IFRS S2 greenhouse gas requirements apply from 1 January 2027 |
| GRI Standards | Voluntary, any organisation | Universal Standards 2021 in effect since 1 January 2023 | GRI 102 Climate Change and GRI 103 Energy take effect on 1 January 2027 |
| VSME and the EU voluntary standard | Voluntary for companies outside the CSRD. Sets the ceiling for CSRD value chain requests | Voluntary standard in force since 24 September 2026 | Value chain cap applies from FY2027 |
| CDP and EcoVadis | Companies asked by customers or investors | Annual cycle | Market requirement, not law |
The CSRD after Stop-the-clock and Omnibus I
The Stop-the-clock Directive (EU) 2025/794 of April 2025 postponed reporting for the second and third waves of companies by two years. The content changes followed in Directive (EU) 2026/470, the Omnibus I Directive, published on 26 February 2026. It limits mandatory reporting to companies with more than 1,000 employees and more than EUR 450 million net turnover, removes listed SMEs from scope and drops the planned move to reasonable assurance.
Member States may exempt first-wave companies that fall below the new thresholds for financial years 2025 and 2026. The revised ESRS, Delegated Regulation (EU) 2026/1563, were published in the Official Journal on 21 September 2026 and are mandatory for financial years beginning on or after 1 January 2027. EFRAG's advice cut mandatory datapoints by around 61%. Our CSRD and ESRS reporting service covers this in detail.
TSRS reporting in Turkey
The Public Oversight, Accounting and Auditing Standards Authority (KGK) published TSRS 1 and TSRS 2 on 29 December 2023. They mirror IFRS S1 and S2 and apply to reporting periods beginning on or after 1 January 2024. A KGK decision published on 16 January 2026 doubled the size thresholds for periods from 1 January 2025, and a decision published on 22 October 2026 extended the timing and climate-only reliefs to 2026 reports. See our TSRS and ISSB reporting service for the full scope rules.
Suppliers and value chain requests
Most Turkish companies will never fall under the CSRD or TSRS directly, but they will be asked for data. From financial year 2027 a CSRD reporter cannot require more than the datapoints listed in Annex II of the EU voluntary standard (Delegated Regulation (EU) 2026/1560) from a value chain company with 1,000 employees or fewer. The cap only covers information gathered for the customer's own CSRD report. It does not limit requests needed under other laws, such as CBAM embedded emissions data. We explain the practical effect in what suppliers must report after the CSRD Omnibus.
Double materiality and materiality assessment
Materiality decides what goes into the report, so it is the step auditors test first. The frameworks use different lenses. The ESRS require double materiality, meaning a topic is reported if it is material from the impact side (your effect on people and the environment) or the financial side (its effect on your cash flows, cost of capital or access to finance). TSRS and IFRS S1 use financial materiality only. GRI uses impact materiality.
A typical assessment for a manufacturer with three to ten sites follows these steps.
- Map the business model, the legal entities in scope and the upstream and downstream value chain (1 to 2 weeks).
- Build a long list of impacts, risks and opportunities from the ESRS topic list, sector peers, permits, incident records and customer requests (1 to 2 weeks).
- Engage stakeholders through interviews with management, workers' representatives, key customers, suppliers and lenders (2 to 3 weeks).
- Score impacts on scale, scope, irremediable character and likelihood, and score risks and opportunities on financial magnitude and likelihood over short, medium and long time horizons (1 to 2 weeks).
- Set thresholds, validate the result with the board or audit committee, and write the methodology note the assurance provider will read (1 week).
The revised ESRS allow a top-down approach and the use of reasonable and supportable information available without undue cost or effort. That helps first-time reporters, but the logic still has to be documented. A list of material topics without the scoring behind it will not pass limited assurance.
ESG data collection and KPIs
Data collection takes the most time in any first report. In a Turkish group the figures sit in many places, such as distribution company invoices, natural gas meter readings, SGK (social security) records, occupational health and safety logs, stack emission measurement reports and annual waste declarations to the Ministry of Environment, Urbanisation and Climate Change. We bring them into one controlled data set.
| Topic | Typical KPIs | Usual source in Turkey |
|---|---|---|
| Climate and energy | Scope 1, 2 (location and market based) and 3 emissions in tCO2e, GHG intensity, energy use in MWh, renewable share | Fuel purchase records, meter readings, electricity invoices, YEK-G or I-REC certificates, supplier data |
| Pollution | NOx, SO2 and dust emissions, substances of concern | Emission permit measurements, SDS inventory |
| Water | Withdrawal and discharge in m3 by source, use in water-stressed areas | Meter readings, discharge permits, municipal invoices |
| Resource use and waste | Waste in tonnes by type and treatment route, recycled input share | Waste declarations, licensed contractor records |
| Own workforce | Headcount by gender and contract, turnover, recordable injuries, training hours, pay gap | SGK filings, payroll, HR system, OHS records |
| Business conduct | Anti-corruption training coverage, confirmed incidents, payment terms to suppliers | Compliance function, finance system |
For each site we issue a data request that names the owner, unit, frequency and evidence for every figure. We then reconcile totals against financial records and keep an audit trail from the source document to the reported number. Greenhouse gas figures follow the GHG Protocol and ISO 14064-1, which our corporate carbon footprint service covers.
ESG report drafting and structure
The framework sets the structure. An ESRS sustainability statement sits in the management report and is organised into general, environmental, social and governance sections. Digital tagging has been postponed until the detailed tagging rules are adopted. TSRS and IFRS S1 reports follow four pillars (governance, strategy, risk management, and metrics and targets) inherited from the TCFD recommendations.
A GRI report is built around GRI 2 general disclosures, GRI 3 material topics and a content index. We draft in English, Turkish or both, prepare the ESRS reference table or GRI content index, and check that figures such as headcount, revenue and capital expenditure match the financial statements. Disclosures written for one framework can often be mapped to another. Our article on ESG reporting frameworks compared shows where they overlap.
Assurance readiness
CSRD sustainability statements need limited assurance. Omnibus I removed the planned step to reasonable assurance, and the Commission must adopt a limited assurance standard by 1 July 2027. In Turkey, TSRS reports of in-scope entities are subject to mandatory assurance by independent auditors authorised by KGK.
Ekol Çevre is a consultant and does not issue assurance opinions. We prepare you for the assurance provider. That means methodology notes for each KPI, an evidence file that links every number to its source, a description of internal controls over ESG data and a pre-assurance review that tests a sample the way an auditor would. During fieldwork we answer the auditor's technical questions on emission factors, boundaries and estimates.
Supplier ESG questionnaires such as CDP and EcoVadis
Many Turkish exporters meet ESG reporting first through a customer request. CDP runs an annual disclosure cycle covering climate change, water and forests, and its questionnaire has been aligned with IFRS S2 since 2024. Suppliers usually respond through CDP's supply chain programme at a customer's request and receive a score from A to D-.
EcoVadis rates companies on 21 criteria grouped into four themes (environment, labour and human rights, ethics, and sustainable procurement). The score depends heavily on documents uploaded, so a written policy with no evidence of implementation scores poorly. Customer portals, sector schemes such as Together for Sustainability in chemicals, and spreadsheet templates sent by buyers add to the load.
We answer these questionnaires and, more usefully, build one evidence library that serves all of them. The same energy data, GHG inventory, policies and training records then feed CDP, EcoVadis, customer templates and the EU voluntary standard datapoints, so each new request takes days rather than weeks.
How an ESG reporting project runs
- Scoping and gap analysis. We confirm which frameworks apply, review existing reports and data, and agree the reporting boundary (2 to 3 weeks).
- Materiality assessment, as described above (4 to 8 weeks).
- Data collection design and the first data round across sites, running in parallel with materiality (6 to 10 weeks).
- KPI calculation, including the greenhouse gas inventory and Scope 3 screening (3 to 6 weeks).
- Drafting, management review and sign-off (4 to 6 weeks).
- Pre-assurance review and support during the auditor's fieldwork (3 to 6 weeks).
A first report usually takes five to eight months from kick-off to publication. The second year is shorter because the materiality assessment only needs updating and the data templates already exist.
What we need from you
- Group structure, list of legal entities and the consolidation scope used in the financial statements
- List of sites with activities, production volumes and permits
- Twelve months of fuel, electricity, steam and water data by site
- HR data from payroll and SGK records, plus OHS incident logs
- Existing policies (code of conduct, anti-bribery, environmental, OHS, human rights, supplier code)
- Previous sustainability reports, CDP or EcoVadis responses and customer questionnaires received
- A named internal coordinator and access to site managers
Cost and timeline drivers
We price each project after scoping. The main drivers are the framework (a full ESRS statement is far larger than a VSME report), the number of legal entities and sites, and the number of material topics. Other drivers are the depth of the Scope 3 inventory, the quality of existing data, the number of report languages and the auditor's timetable.
Questionnaire work is priced per cycle and gets cheaper once the evidence library exists. Clients with an existing ISO 14064-1 inventory or a GRI report usually need far less work in the first year.
Why a Turkey-based ESG reporting team helps
Ekol Çevre has more than 20 years of experience in environmental impact assessment, permits, chemicals management, greenhouse gas accounting and sustainability reports. Our offices in İzmir, Ankara and Kocaeli are close to the main industrial zones, so we can visit plants rather than rely on spreadsheets sent by email.
We read Turkish permits, measurement reports and SGK data in the original and speak to plant managers and suppliers in Turkish. We also work daily with KGK rules and EU legislation. For EU parents this means fewer gaps in subsidiary data. For Turkish exporters it means one team that also handles CBAM consulting and product carbon data requested by EU buyers.