Sustainability reporting in Turkey is no longer just a voluntary ESG brochure; It is a legal disclosure obligation for companies of a certain size. Türkiye Sustainability Reporting Standards (TSRS), published by the Public Oversight, Accounting and Auditing Standards Authority (KGK), are prepared in line with the IFRS sustainability line. Particularly for TSRS 2 (climate disclosures), energy consumption, Scope 1–2 emissions and — if important — Scope 3 data must be measurable; Predictive reports are inadequate for auditing and supplier demands.
2 / 3 criteria
Threshold (2026 update)
Two consecutive periods — table below
≥ 1 billion TL
Total assets
16.01.2026 KGK decision
≥ 2 billion TL
Net sales revenue
16.01.2026 KGK decision
≥ 500
Number of employees
Previous threshold: 250 people
What is TSRS, who reports it?
TSRS; It entered into force for accounting periods beginning on January 1, 2024, with the decision of the KGK published in the Official Gazette on December 29, 2023. It consists of two main standards: TSRS 1 (general requirements for sustainability-related financial information) and TSRS 2 (climate-related disclosures, compatible with IFRS S2). In the first reports during the transition period, the implementation of TSRS 2 was deemed sufficient; The full scope of TSRS 1 expands over time.
Obligation; It depends on the evaluation of size thresholds along with POA lists (capital market, banking, etc.). Companies on the list that do not meet the thresholds may be exempt from reporting; Those who meet the thresholds for two consecutive periods are liable. With the update published on January 16, 2026, asset, turnover and employee thresholds were increased by one fold (500 million → 1 billion TL assets; 1 billion → 2 billion TL turnover; 250 → 500 employees).
TSRS vs GRI vs CSRD/ESRS
| feature | TSRS (Türkiye) | GRI Standards | CSRD/ESRS (EU) |
|---|---|---|---|
| basis | POA — legal (in scope) | Voluntary/market demand | EU directive — legal |
| structure | TSRS 1 + TSRS 2 (IFRS compliance) | Universal + sectoral issues | ESRS subject standards (E1 climate etc.) |
| climate/energy | TSRS 2 — emissions, target, transition plan | GRI 305 emissions | ESRS E1 — climate change |
| Financial connection | Cash flow, cost of capital impact | Materiality focused | Double materiality |
| Assurance | Sustainability audit (staged) | Optional third-party | Mandatory limited → reasonable |
| Türkiye exporter | Local legal compliance | Customer/NGO request | EU sales/supply chain edition |
Reporting schedule: from 2024 data to 2026
The TSRS compliant sustainability report must be published simultaneously and covering the same period as the relevant financial statements. Within the scope of ease of transition, the publication period of the first reports for the 2024 activity period has been extended until October 31, 2025. The general rule for businesses that do not submit interim financial reports is to publish the report no later than nine months following the annual period.
- 2024 data — first TSRS report: 31.10.2025 deadline (transition extension)
- 2025 data (closing 31.12.2025): typical deadline September–October 2026
- Special accounting period: 10 months from the end of the period (POA temporary provisions)
- A sustainability section can be added after the financial statements are published (Provisional article 2)
TSRS 2 and climate: energy, Scope 1–2 data needs
TSRS 2; It requires climate disclosure in four pillars: governance, strategy, risk management and metrics-targets. The metrics section includes the greenhouse gas inventory (Scope 1 direct, Scope 2 purchased energy), energy consumption, emissions reduction targets, and — if applicable — transition plan. Location-based annotation is mandatory for Scope 2; If a market-based YEK-G or contractual instrument is used, it should be stated separately.
The backbone of Scope 2 for industrial facilities is the purchased electricity (kWh) and the emission factor. On the Scope 1 side, natural gas, fuel oil, process emissions and field vehicle fuel should be supported by invoices/meters. Our Carbon Neutral, Net Zero and Scope 1–2–3 guide explains these concepts in detail; TSRS 2 report is the official disclosure format of this inventory.
Where is the supply chain (Scope 3) in TSRS?
TSRS 2 requires disclosure of Scope 3 for categories that are “significant to the company” in line with IFRS S2. Items such as purchased goods and services, logistics, business travel and use of the product sold may be dominant in the automotive, machinery and chemical sectors. Although the Scope 3 exemption was granted for certain non-bank financial institutions during the transition period with the decision of the POA on December 16, 2024, the export industry and EU buyers do not agree to settle for spend-based estimation.
Data checklist: what is pulled from which system?
| data field | Typical welding | Quality grade |
|---|---|---|
| Scope 2 — electricity (kWh) | OSOS, distribution invoices | 12 months agreement; location based factor |
| Scope 1 — natural gas / fuel | Invoice, meter, ERP | Align EIVER inventory with TEP conversion |
| Scope 1 — process / cooler | Mass balance, leak test | Auditable documentation |
| Energy density (kWh/ton) | OSOS + production ERP | EnPI; Common with ISO 50001 |
| Scope 3 — purchase | ERP, supplier survey | Spend-based → activity-based transition |
| target tracking | Annual GHG inventory | Base year + recovery projects |
ENOPTIMAL: consumption data → reporting input
The “metrics and targets” section of TSRS 2 calls for a consistent chain of measurements rather than concatenated invoices in Excel. ENOPTIMAL consumption management module feeds Scope 2 and energy intensity KPIs with OSOS integration, multi-site consumption summary, invoice verification and reagent/anomaly alarms; kWh/product is normalized with the production module. The same data set can be used in parallel with EIVER, ISO 50001 and carbon inventory — report = measurable data.
Conclusion
TSRS obligation in 2026; It requires significant data infrastructure along with updated thresholds, TSRS 2 climate disclosures and sustainability assurance auditing. Scope analysis (list + threshold + two-period rule) should be performed first, followed by Scope 1–2 inventory and OSOS reconciliation. By requesting a demo, you can receive a TSRS data maturity assessment specific to your facility.