Turkey TSRS
KGK Board Decision No. 21634 on application of Turkish Sustainability Reporting Standards (TSRS 1, TSRS 2)
Topic : ESG disclosure · Level : National
Today
TSRS mandatory for in-scope entities; thresholds raised Jan 2026. Oct 2026 reliefs: 2026 reports up to 9 months after year-end.
Summary
Turkey made ISSB-based TSRS reporting mandatory for large entities from 2024. In January 2026 the KGK raised the thresholds to two of: TRY 1bn assets, TRY 2bn sales, 500 employees. Borsa Istanbul's guide stays voluntary.
Who is concerned
- Turnover
- Net sales > TRY 2 bn (2 of 3 criteria)
- Employees
- > 500 average (2 of 3 criteria)
- Listed company
- cotées et non cotées
- Sectors
- All sectors
- Banks, capital markets firms
- Triggering activities
- 2 of 3: assets 1bn, sales 2bn TRY, 500 staff
- Criteria met two consecutive periods
- Extraterritorial reach
- No
Turkish entities only; value-chain data (Scope 3 under TSRS 2) flows to foreign suppliers.
- Examples
- Turkish textile exporter with 800 staff
- Borsa Istanbul-listed automotive supplier
What the law requires
- Prepare sustainability report under TSRS 1 and TSRS 2 (IFRS S1/S2)
- Disclose Scope 1, 2 and, after relief, Scope 3 emissions
- Obtain independent assurance from a KGK-authorised auditor
Penalties
No TSRS-specific fines. Non-filing breaches the KGK decision (TTK art. 88); board liability under TTK art. 553; CMB rules on misleading disclosure.
What this changes for a supplier in China
Turkish textile, auto and appliance makers buy heavily from China. Their TSRS 2 Scope 3 work drives data requests to Chinese yarn, component and chemical suppliers.
Expected evidence
- Product carbon footprint per shipment
- Scope 1-2 inventory of factory
- Energy mix and electricity certificates
Tiers : Tier 1-2