TSRS reporting in 2026: who is in scope, when and how?

01What is TSRS?

TSRS are the sustainability reporting standards issued by Türkiye’s Public Oversight, Accounting and Auditing Standards Authority (KGK), aligned with the international ISSB standards (IFRS S1 and IFRS S2). TSRS 1 covers general disclosures on sustainability-related risks and opportunities, and TSRS 2 covers climate-related disclosures. The aim is to let investors and lenders see, on a comparable basis, the sustainability matters that could affect a company’s financial position.

A TSRS report is not a statement of good intentions but a disclosure linked to the financial report: it asks for concrete information on governance, strategy, risk management, and metrics and targets.

02Who is in scope?

Under KGK’s scope decision no. 21634, the obligation is tied to size criteria for certain types of company:

• Listed companies and other entities supervised by the Capital Markets Board (SPK),
• Banks (regardless of thresholds) and other financial institutions supervised by the Banking Regulation and Supervision Agency (BDDK),
• Insurance, reinsurance and pension companies,
• and other companies that exceed the size criteria.

For the size test, a company must exceed at least two of the three criteria below in two consecutive reporting periods. KGK’s decision published in the Official Gazette on 16 January 2026 updated the thresholds for periods beginning on or after 1 January 2025 as follows:

1. Total assets: TRY 1 billion (previously TRY 500 million)
2. Annual net revenue: TRY 2 billion (previously TRY 1 billion)
3. Number of employees: 500 (previously 250)

Because the thresholds went up, some mid-sized companies may have dropped out of scope. Being out of scope does not mean the requests for data stop, though: banks, investors and EU customers keep asking their suppliers for the same information.

03Transition reliefs for the first report

• Comparative information: no comparative information for the previous period is required in the first reporting period.
• Timing of publication: the first report may be published after the financial statements (together with the interim report or within a set period).
• Climate first: in the first period companies may choose to focus on climate-related disclosures (TSRS 2) only.
• Scope 3 emissions: disclosure of Scope 3 greenhouse gas emissions is not required in the first two reporting years.

In October 2026 KGK issued an update on applying some transition reliefs to the 2026 period as well. When planning your report, always check the current decision text on KGK’s website.

04What should the report contain?

• Governance: how the board and senior management oversee and manage sustainability and climate risks.
• Strategy: short-, medium- and long-term risks and opportunities; their effects on the business model, value chain and financial position; climate scenario analysis.
• Risk management: the processes for identifying, assessing and monitoring risks.
• Metrics and targets: Scope 1 and 2 (later Scope 3) emissions, industry-specific indicators and the targets the company has set.

05What should you do now?

1. Check your scope: compare total assets, revenue and headcount for the last two periods with the new thresholds.
2. Assign ownership: decide who owns the report across finance, sustainability and risk teams, and bring the board into the process.
3. Identify material risks and opportunities: assess the climate and sustainability issues in your sector together with their financial effects.
4. Strengthen your emissions data: build your Scope 1 and 2 inventory and start collecting Scope 3 data now.
5. Prepare for assurance: document data sources, calculation methods and controls, and follow KGK’s rules on assurance engagements.