For the past two years, manufacturers selling into Europe kept hearing the same request: “Can you share your sustainability data?” Behind that question stood the EU’s Corporate Sustainability Reporting Directive (CSRD). In 2026, things shifted. The EU reworked its own reporting rules through a simplification package known as “Omnibus.” Thresholds went up, the number of required datapoints came down, and a cap now protects smaller suppliers.
This matters directly to exporters and suppliers in Türkiye. Most Turkish manufacturers are not subject to CSRD themselves — but their large EU customers are, and those customers push data requests down the supply chain. Omnibus changed the rules of exactly that pass-through. Below is a plain summary of what happened and what you should do next.
What CSRD was, and what Omnibus changed
CSRD was the EU directive requiring companies above a certain size to report their environmental and social impact in a standard format (ESRS — the European Sustainability Reporting Standards). In its first version the scope was broad and the number of datapoints ran close to a thousand.
The European Commission bundled a series of changes into a single “Omnibus” package, aiming to boost competitiveness and cut administrative burden. The package was published in the EU Official Journal on 26 February 2026 and entered into force twenty days later, in mid-March 2026. (Source: EU Official Journal; for technical summaries, the Omnibus I client alerts from law and audit firms.) It moved in three directions: it narrowed scope, reduced the data required, and pushed back the timeline.
New thresholds: who stayed in, who dropped out
The most visible change was the scope threshold. The table below compares the old and new positions. Because figures and dates can still be updated with the final ESRS text, verify the current official version before making a decision about your own company.
| Previous criterion | After Omnibus | |
|---|---|---|
| Employees | 250 (with other thresholds) | More than 1,000 |
| Net turnover | €50 million | More than €450 million |
| How applied | Meet one of two criteria | Exceed both thresholds together |
The result: scope was limited to the largest companies only. Companies that had already started reporting but fall below the new thresholds dropped out. The number of mandatory datapoints is also being redrawn to fall from the eleven-hundred-plus level to roughly a third of that; the revised ESRS text is expected within 2026. For the exact count and effective date, it is best to follow European Commission announcements.
The most important change: the supply-chain cap
Here is the clause that matters most for Turkish exporters. Omnibus limited the information that large reporting companies can request from their suppliers. A “value-chain cap” now prevents companies from demanding data beyond the voluntary VSME standard (a simplified standard for small and medium-sized enterprises) from suppliers with fewer than a thousand employees.
In practice this means your EU customer can no longer impose every detail in any format they like. The request is bounded by a reasonable, standard framework. For SMEs with limited data-collection capacity, that is a real relief. But it does not mean the request disappears — your customer will still ask for your carbon footprint and basic environmental indicators.
The Türkiye side: TSRS and the exporter’s real agenda
Türkiye built its own framework. The Turkish Sustainability Reporting Standards (TSRS) became mandatory from 1 January 2024 for companies above a defined threshold. The Turkish criteria announced by the Ministry of Trade rest on meeting at least two of: 250 employees, TRY 500 million in assets, and TRY 1 billion in annual net sales. (Source: Ministry of Trade, Green Deal pages.)
For an exporter the picture is clear: data requests come from both sides. On one side, EU customers and the CSRD chain; on the other, domestic legislation and TSRS. Add to that the start of the Carbon Border Adjustment Mechanism (CBAM) definitive period in early 2026. Three separate agendas ask the same basic question: can you measure your production’s environmental data? That is why CBAM and carbon reporting now sit at the centre of green transition.
What should an exporting SME do?
Omnibus lightened the load, but it did not remove the agenda. Concrete steps to take today:
- Clarify whether you are in scope. Even if you are not directly under CSRD, ask your EU customer up front what they will require from you. Close the uncertainty by talking to the customer, not by guessing.
- Measure your carbon footprint. Calculating your Scope 1, 2 and 3 emissions is the shared basis for both CBAM and customer requests.
- Keep the data in one place. Emissions, energy and production data scattered across different spreadsheets is the most common problem. When a request arrives, keep the data inside a system instead of hunting through files for days.
- Know the VSME framework. If you are a small supplier, the data your customer can ask for is bounded by this standard. If you feel pressure to report more, know where the limit is.
- Follow the official source. The post-Omnibus ESRS text and dates are settling; base critical decisions on current European Commission and Ministry of Trade announcements.
From measuring to reporting: putting the data in order
The common thread across these rules is not the report itself, but the data underneath it. Even as the report format is simplified, the need to produce reliable emissions and energy data remains. İkiz Eksen’s approach starts exactly there: first make production and energy data measurable on the shop floor, then gather it in a software layer, and finally turn it into output aligned with CBAM and customer requests.
Behind this measure–software–compliance chain is Qera’s enterprise software track record: more than 550 customers across over 15 sectors and more than 100 ERP implementations. The infrastructure runs on Microsoft Azure, with an information-security and quality framework built on ISO/IEC 27001 and ISO 9001 certification. Steps that require specialist expertise — from sensor deployment to accredited carbon verification — we carry out with solution partners, and we set out who provides what transparently on our solutions page.
In short: Omnibus reduced the reporting burden sensibly. But the measurement agenda for any manufacturer selling into Europe is still on the table. Put your data in order today and you will be ready whatever request arrives. If you would like to talk about where to start, get in touch.
Frequently Asked Questions
If I am not in CSRD scope, why does Omnibus concern me?
Because your EU customer may be in scope and can pass the data request down to you. Omnibus limited that pass-through: if you have fewer than a thousand employees, you cannot be asked for data beyond the VSME standard. So even without being directly subject, the rule has a side that protects you.
Now that Omnibus is out, do I no longer need to prepare carbon data?
You do. Omnibus reduced the scope and the datapoints of the report; it did not remove the need to measure. The CBAM definitive period started in 2026 and EU customers keep asking for basic emissions data. Measuring your carbon footprint is still necessary.
What exactly is the new CSRD threshold?
After Omnibus, scope is limited to companies with more than a thousand employees and more than €450 million in net turnover. The earlier, lower thresholds were raised. Because the exact conditions can be updated with the final text, confirm your own situation against the official EU source.
Are TSRS and CSRD the same thing?
No. CSRD is the European Union’s framework; TSRS is Türkiye’s sustainability reporting framework. TSRS has been mandatory since 1 January 2024 for Turkish companies above a defined threshold. If you export, you may face requests from both sides — and both rest on the same measurable data.
How do I start preparing for this process?
First clarify what your EU customer will ask of you, then make your production and energy data collectable in one place. Setting up measurement helps you whatever legislation arrives. You can find how to sequence the digital steps on our digital transition page.