Turkish exporters after the CSRD Omnibus: what data will EU customers ask for?

01What changed with Omnibus I?

The Omnibus I directive amending the Corporate Sustainability Reporting Directive (CSRD) was published in the EU Official Journal on 26 February 2026 and entered into force on 18 March 2026. Member states must transpose the changes into national law by 19 March 2027. The main changes:

• Narrower scope: EU companies will report only if they exceed both thresholds of an average of more than 1,000 employees and net turnover above €450 million.
• Listed SMEs are now out of scope.
• Limited assurance remains mandatory; the planned move to reasonable assurance has been dropped.
• Value-chain cap: companies with 1,000 employees or fewer can refuse requests for information that go beyond the voluntary standard.

02When will your EU customers report?

1. First wave: some of the large companies reporting since 2024 (those with 500–1,000 employees) drop out of scope from 2027; the rest continue to report.
2. Newly covered large companies: under the “stop-the-clock” postponement, they will publish their first reports in 2028 for financial year 2027.
3. Non-EU parent companies: groups with EU turnover above €450 million in two consecutive years and an EU subsidiary or branch with turnover above €200 million will report in 2029 for financial year 2028.

In short, most of your large EU buyers are starting to collect 2027 data now. Supplier questionnaires and contract clauses will become more frequent on this timeline.

03What data can suppliers be asked for?

A company in scope of the CSRD must report on impacts and risks in its value chain, which means asking suppliers for data. To protect value-chain partners with fewer than 1,000 employees, Omnibus I limits these requests to information based on the voluntary SME standard (built on EFRAG’s VSME standard). Requests to Turkish suppliers are therefore likely to focus on:

• Energy use and Scope 1–2 greenhouse gas emissions, ideally with product-level carbon footprints,
• Water, waste and pollution indicators,
• Occupational health and safety, headcount and basic working conditions,
• Business ethics, anti-bribery measures and the existence of policies.

The cap gives legal protection, but commercial reality is different: a supplier that cannot provide data may fall behind in purchasing decisions.

04Overlap with other regulations

• CBAM: product-level embedded emissions data is already mandatory for exporters of iron and steel, aluminium, cement, fertilisers, electricity and hydrogen.
• CSDDD: Omnibus I raised its scope to more than 5,000 employees and €1.5 billion turnover, with compliance obligations starting from July 2029. Large buyers will keep passing human rights and environmental risk screening down to suppliers.
• TSRS: for companies in scope in Türkiye, ISSB-aligned reporting means the same data must also be prepared domestically.

05What should you do now?

1. Map your customers: list the CSRD timelines and supplier requests of your largest EU buyers.
2. Prepare a VSME-aligned data pack: collect energy, emissions, water, waste, health and safety and governance data in one standard format.
3. Build an emissions inventory: start with Scope 1 and 2, then move to carbon footprints for your main products.
4. Document your policies: put your environmental, business ethics, human rights and supply chain policies in writing.
5. Strengthen your evidence: keep traceable data records ready for customer audits and possible assurance requests.