Over the past three years, sustainability reporting has shifted from a voluntary goodwill gesture to a legal obligation for companies above a certain size. The rules were redrawn again in early 2026 on both sides: Türkiye raised the size thresholds that pull a company into scope, and the EU markedly narrowed the scope of CSRD. On the surface, both headlines read as “less burden.” For manufacturers, the reality is a little more nuanced.
This article gathers, with sources, who must report, exactly what changed in 2026, and why it still concerns you even if you fall outside scope.
What is TSRS, and who is in scope?
The Turkey Sustainability Reporting Standards (TSRS) were issued by the Public Oversight, Accounting and Auditing Standards Authority (KGK) and took effect with their publication in the Official Gazette on 29 December 2023. The standards are built on the international ISSB framework — IFRS S1 (general sustainability disclosures) and IFRS S2 (climate-related disclosures) — so TSRS 1 sets the general frame and TSRS 2 covers the climate chapter.
Reporting is mandatory for entities that exceed certain size thresholds across two consecutive reporting periods. The logic is simple: if you exceed at least two of the three criteria below, you are in scope.
| Criterion | What it measures |
|---|---|
| Total assets | Balance sheet size |
| Annual net sales revenue | Yearly turnover |
| Number of employees | Headcount |
Financial institutions regulated by the banking and capital-markets authorities (BDDK and SPK) — banks, insurers, capital-markets firms — are assessed in scope regardless of these numeric thresholds, with temporary exemptions granted to some smaller entities. To clarify your own position, rely on KGK’s sustainability page and your financial adviser.
The 2026 change: thresholds doubled
Here is the real news. The KGK Board Decision updating the threshold criteria was published in the Official Gazette on 16 January 2026 and applies to accounting periods beginning on or after 1 January 2025. The new thresholds are exactly double the previous figures:
- Total assets: TRY 500 million → TRY 1 billion
- Annual net sales revenue: TRY 1 billion → TRY 2 billion
- Number of employees: 250 → 500
In practice this means a set of mid-sized companies that were in scope under the old thresholds drop out of the mandatory reporting obligation if they no longer exceed at least two criteria. Since these figures are revised periodically, confirm the current Board Decision and an independent auditor/adviser opinion when you run your own calculation.
One point matters: leaving scope does not mean the need to keep sustainability data disappears. We’ll explain why shortly.
On the EU side: Omnibus narrowed scope, pressure remains
A similar simplification took place in the EU. The simplification directive known as “Omnibus I” was published in the Official Journal of the EU on 26 February 2026 and entered into force on 18 March 2026. The directive substantially narrowed the mandatory scope of the Corporate Sustainability Reporting Directive (CSRD) and its associated ESRS standards.
Under the new threshold, ESRS-aligned reporting is broadly limited to EU companies with more than 1,000 employees and net turnover above EUR 450 million — far above the previous 250-employee threshold. The number of data points in the standards was also cut significantly; the simplified ESRS text is expected to be finalized in autumn 2026, with the first reports under the simplified standards covering financial year 2027. These figures rest on EU legislation; for exact conditions, rely on the official text or a compliance adviser.
At first glance it looks like “Europe backed off.” But large customers’ habit of requesting data from their suppliers is not erased by a single directive clause.
The “I’m not in scope” trap: the supply-chain effect
Most manufacturing SMEs in Türkiye exceed neither the TSRS nor the ESRS thresholds directly. Even so, the demand for sustainability data reaches them indirectly.
The logic is straightforward: if a large in-scope company must report its own carbon footprint and value-chain emissions (Scope 3), it has to collect that data from its suppliers. So even if you don’t report, your reporting customer asks you for emissions, energy and material data. The same pressure awaits exporters to the EU on the CBAM front, which we covered separately in our CBAM definitive period guide.
The takeaway: being below the mandatory threshold doesn’t make you a “non-measuring” company — it merely defers your obligation to file in an official format. The data request keeps arriving at your door as a tender and contract condition.
Not a report, a data system: start with measurement
The most common mistake in sustainability reporting is treating it as a document prepared once a year. The report is the output. The real work is building the continuous, reliable data flow that feeds it:
- Emissions data: Drawing Scope 1, 2 and 3 boundaries correctly and collecting them regularly. Our carbon footprint guide is a good starting point.
- Energy and consumption data: Monitoring electricity, fuel and water use at meter and system level.
- Production and process data: Capturing machine and production data so you can see resource use per unit of output.
- Traceable records: Data that is auditable, consistent over time, and clearly sourced.
These four layers can run on hand-kept spreadsheets for a while, but they only reach the reliability needed to withstand an audit and a customer query through software infrastructure. With limited assurance audits of TSRS reports coming onto the agenda in 2026, the question of “where the data came from” becomes even more critical.
The İkiz Eksen approach: measure, transform, sustain
This is exactly where İkiz Eksen’s work begins: building a chain that first measures, then transforms the process, and finally makes it sustainable. On the green transition side we make carbon and energy data measurable; on the digital transition side we connect the processes that produce this data to ERP and automation infrastructure. The payoff of running both axes together is turning the report from an end-of-season scramble into a natural output of daily work.
This experience isn’t conjured from thin air. The field experience of our sister company Qera — over 550 customers, more than 15 sectors and 100-plus ERP deployments — a roughly 35-person expert team, and Microsoft Azure infrastructure let us keep sustainability data in the same system as real production data. We deliver the service across Türkiye, as turnkey projects.
In scope or not, if you want to build sustainability data as a lasting capability rather than a one-off project, take a look at our solutions or get in touch directly. When the terminology gets dense, our glossary is there too.
Frequently Asked Questions
Am I in TSRS scope?
You are in scope if you exceed at least two of these three for two consecutive periods: total assets of TRY 1 billion, annual net sales revenue of TRY 2 billion, and 500 employees (the current thresholds published in the Official Gazette on 16 January 2026). Financial institutions are assessed independently of these numbers. Confirm your exact status with your financial adviser and the current Board Decision.
Are TSRS and CSRD/ESRS the same thing?
Both sit close to the same international foundation (ISSB and EU frameworks), but they are different regulations. TSRS is applied in Türkiye by KGK, while CSRD/ESRS apply in the EU. Firms exporting to the EU or belonging to an EU group company may need to track both sides.
If the thresholds rose, do I no longer need to do anything?
No. Falling outside mandatory reporting doesn’t stop your customers and tenders from asking you for data. Large in-scope customers collect supplier data to report their Scope 3 emissions; that demand is independent of the threshold.
What do I need first for a report?
Data before the report. A system that regularly and auditably collects carbon footprint (Scope 1-2-3), energy and production consumption data. The report is an orderly summary of that data.
What does İkiz Eksen do in this process?
We set up the measurement infrastructure, digitalize the processes that produce the data, and turn reporting into an output of daily work. You can start by sharing your current situation through our contact page.