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What TSRS reporting is
TSRS reporting is mandatory sustainability reporting in Turkey under the Turkish Sustainability Reporting Standards issued by the Public Oversight, Accounting and Auditing Standards Authority (KGK). TSRS 1 sets general requirements for sustainability-related financial information and TSRS 2 covers climate. Both are aligned with the ISSB's IFRS S1 and IFRS S2.
We help two kinds of client. Turkish companies that fall into the KGK scope need a compliant report and an assurance-ready file. Foreign-owned subsidiaries in Turkey need to know whether they are in scope at all, and if so, how to produce a TSRS report that matches what the parent already discloses under the ISSB standards or the ESRS.
Who must report under TSRS in 2026
The scope is set by KGK Board decisions rather than by the standards themselves. Only entities in the named categories are covered. Other companies, however large, are outside the mandatory scope and may apply TSRS voluntarily.
| Category | Examples | Size thresholds |
|---|---|---|
| Capital market entities | Companies whose shares or other capital market instruments trade on an exchange, issuers with a valid prospectus or issuance certificate, companies issuing debt instruments by private placement, investment firms, portfolio management companies | Apply |
| Banks | All banks except those under the Savings Deposit Insurance Fund (TMSF) | Do not apply |
| Other regulated financial entities | Leasing, factoring and financing companies, asset management companies, financial holding companies, companies with qualifying holdings in banks | Apply |
| Insurance | Insurance, reinsurance and pension companies | Apply |
| Precious metals | Precious metals intermediaries and companies producing or trading precious metals in Borsa İstanbul markets | Apply |
Where thresholds apply, an entity is in scope if it exceeds at least two of the three criteria below in two consecutive reporting periods, measured together with its subsidiaries and associates. The new figures come from a KGK decision published in the Official Gazette on 16 January 2026 and apply to periods beginning on or after 1 January 2025.
| Criterion | Original threshold (2023 decision) | Threshold from 2025 periods |
|---|---|---|
| Total assets | TRY 500 million | TRY 1 billion |
| Annual net sales revenue | TRY 1 billion | TRY 2 billion |
| Number of employees | 250 | 500 |
An entity leaves the scope if it stays below two criteria for two consecutive periods, or falls 20% or more below two criteria in a single period. KGK publishes a calculation tool (KGK-SÜHA) on its sustainability page for the scope test.
TSRS timeline and transition reliefs
| Date | Development |
|---|---|
| 29 December 2023 | TSRS 1, TSRS 2 and the first scope decision published in the Official Gazette |
| 1 January 2024 | First reporting periods begin for in-scope entities |
| 16 January 2026 | Thresholds doubled for periods beginning on or after 1 January 2025 |
| 28 July 2026 | Amendments to TSRS 2 greenhouse gas requirements published, mirroring the December 2025 ISSB amendments to IFRS S2 |
| 22 October 2026 | KGK decision of 19 October 2026 published, extending transition reliefs to 2026 reports |
Under the October 2026 decision, all in-scope entities may publish their 2026 sustainability report after their financial statements (the relief in paragraph E4 of TSRS 1). Entities that already used the climate-first relief in paragraph E5 may limit their 2026 report to the climate disclosures in TSRS 2, and those entities may also omit non-climate comparatives in their 2027 reports. A second decision removed, from 1 January 2026, the optional Scope 3 treatment previously given to small non-listed banks and financial institutions.
Scope 3 emissions do not have to be disclosed in the first two years an entity applies TSRS. Comparative information is not required in the first reporting period.
What TSRS 1 and TSRS 2 require
Both standards follow the four pillars inherited from the TCFD recommendations. Governance covers board oversight and management's role. Strategy covers risks and opportunities, their effect on the business model and financial position, and resilience. Risk management covers how risks are identified and managed. Metrics and targets close the report.
TSRS 1 uses financial materiality. Information is material if omitting or misstating it could reasonably be expected to influence decisions of investors and lenders. It also refers preparers to the SASB Standards for industry-specific topics and metrics. TSRS 2 adds specific climate requirements, including the transition plan, climate resilience, greenhouse gas emissions, industry-based metrics, internal carbon prices and links to executive pay.
Climate risk and scenario analysis
TSRS 2 requires a climate resilience assessment using scenario analysis, with an approach proportionate to the entity's skills and resources. For a Turkish industrial company this usually means at least a high-warming scenario for physical risk and a rapid-transition scenario for transition risk, assessed over short, medium and long horizons.
Physical hazards we typically assess for Turkish sites include extreme heat, drought and water stress (relevant in the Konya basin and much of the Aegean), flooding, wildfire and coastal effects. Transition risks include the EU Carbon Border Adjustment Mechanism, the emissions trading system set up by Turkey's Climate Law No. 7552 of July 2025, customer decarbonisation targets and changes in energy prices. Each risk is linked to a financial line item, for example cost of sales, capital expenditure or asset impairment.
Scope 1, 2 and 3 emissions
Emissions are measured under the GHG Protocol Corporate Standard. Scope 2 is reported location-based, with market-based information where it helps users understand the figures. In Turkey, market-based claims depend on YEK-G guarantees of origin or I-REC certificates.
Scope 3 covers 15 categories. For most manufacturers, purchased goods and services, upstream transport and use or end-of-life of sold products dominate. The 2026 amendments to TSRS 2 let entities limit Category 15 (investments) to certain financed emissions and give relief where a jurisdiction requires a different measurement method. Our ISO 14064-1 corporate carbon footprint work produces an inventory that feeds TSRS 2 directly.
Foreign-owned subsidiaries in Turkey
Many foreign-owned companies in Turkey are non-listed manufacturers or distributors that do not issue capital market instruments. They fall outside the mandatory TSRS scope, whatever their size. Foreign-owned banks, insurers, leasing and factoring companies, and companies with listed shares or bonds are in a different position, and must report in Turkey even if the parent already reports under the ISSB standards or the ESRS.
Because TSRS mirrors IFRS S1 and S2, a parent's ISSB-based climate work can be reused. A parent reporting under the ESRS can map its E1 data to TSRS 2, but the materiality lens differs, so some impact-only topics drop out and some financial effects need more depth. We build one data set and produce both outputs. The CSRD and ESRS reporting page covers the EU side.
How a TSRS project runs
- Scope test against the KGK categories and thresholds, using two years of consolidated figures (1 week).
- Gap analysis of governance, risk management and existing emissions data (2 to 3 weeks).
- Identification of sustainability-related risks and opportunities, with climate scenario analysis (4 to 8 weeks).
- Scope 1 and 2 inventory, and Scope 3 screening ahead of the end of the relief period (4 to 8 weeks).
- Drafting of the TSRS report in Turkish, with an English version for foreign shareholders where needed (3 to 5 weeks).
- Pre-assurance review and support during the independent auditor's work (3 to 6 weeks).
Cost and timeline drivers for TSRS reporting
The largest drivers are the number of consolidated entities and sites, the state of the existing greenhouse gas inventory and the depth of the scenario analysis. A company that only uses the climate-first relief in 2026 needs a smaller first report than one covering all sustainability risks under TSRS 1. Scope 3 work grows quickly with the number of suppliers and product lines, so we usually phase it over the two-year relief period.
Timing follows the financial calendar. Scenario analysis and risk identification should be finished before the year-end close, so that the emissions data and narrative can be completed in the first months after year end.
What we need from you and what you receive
We need two years of consolidated financial statements and employee numbers, board and committee charters, the enterprise risk register, energy and fuel data by site, capital expenditure plans and any existing CDP or sustainability reports. You receive a scope memo, a risk and opportunity register with scenario analysis, the greenhouse gas inventory, the draft TSRS report and an evidence file prepared for the KGK-authorised auditor who carries out the mandatory assurance.
Ekol Çevre is a consultant, not an assurance provider. TSRS sits within our wider ESG reporting services, and our comparison of ESG reporting frameworks shows how TSRS relates to GRI, ESRS and CDP.