TSRS Explained: Türkiye's Sustainability Reporting Standards (2026 Guide)

In short: TSRS (Türkiye Sustainability Reporting Standards) are Türkiye's adoption of the ISSB's IFRS S1 and IFRS S2, issued by the regulator KGK and mandatory for certain companies from 1 January 2024. A company is in scope only if it belongs to a listed entity group (e.g. Borsa Istanbul-listed companies, financial institutions, insurers) and exceeds at least two of three thresholds (TRY 1bn total assets, TRY 2bn net revenue, 500 employees) for two consecutive periods. Banks are in scope regardless of size.

Last updated: 28 October 2026. Includes the KGK decisions for the 2026 reporting period published on 22 October 2026.

What is TSRS?

TSRS are sustainability reporting standards issued by Türkiye's Public Oversight, Accounting and Auditing Standards Authority (Kamu Gözetimi Kurumu, KGK) and published in the Official Gazette on 29 December 2023. They mirror IFRS S1 and IFRS S2 issued by the International Sustainability Standards Board (ISSB), which makes Turkish reports comparable for international investors. Türkiye was one of the first jurisdictions to adopt the ISSB standards on a mandatory basis.

The purpose of TSRS is to tell investors and lenders how sustainability-related risks and opportunities could affect a company's cash flows, access to finance and cost of capital. It complements financial reporting rather than replacing a voluntary CSR report.

TSRS 1 and TSRS 2

	TSRS 1	TSRS 2
Title	General Requirements for Disclosure of Sustainability-related Financial Information	Climate-related Disclosures
Based on	IFRS S1	IFRS S2
Covers	General framework, materiality, reporting entity, timing, all sustainability risks and opportunities	Physical and transition climate risks, opportunities, greenhouse gas emissions
Key content	Governance, strategy, risk management, metrics and targets	Scope 1, 2 and 3 emissions, scenario analysis, climate resilience, transition plans, industry-based metrics

Who must report under TSRS?

KGK Board Decision No. 21634 of 27 December 2023 (as amended) uses a two-step test. Both conditions must be met.

Step 1: Entity group

Group	Entities	Thresholds apply?
Capital markets	Companies whose shares trade on Borsa Istanbul (except the Watchlist Market and the qualified-investor Venture Capital Market), investment firms, collective investment undertakings, mortgage finance institutions, central clearing and custody institutions, data storage institutions	Yes
Banks	All banks regulated by the BRSA, except those under the TMSF	No, always in scope
Non-bank financial institutions	Rating agencies, financial holding companies, leasing, factoring and financing companies, asset management companies, savings finance companies, qualified shareholders of banks/financial holdings	Yes
Insurance and pensions	Insurance, reinsurance and private pension companies	Yes
Borsa Istanbul members	Authorised intermediaries, precious metals brokers, precious metals producers and traders	Yes

Portfolio management companies and unlisted companies that only issue non-equity securities (e.g. bonds) were removed from mandatory scope by the decision of 16 December 2024.

Step 2: Size thresholds

Except for banks, entities must exceed at least two of three criteria in two consecutive reporting periods:

Criterion	2024 periods	Periods from 1 January 2025
Total assets	TRY 500 million	TRY 1 billion
Annual net revenue	TRY 1 billion	TRY 2 billion
Employees (annual average)	250	500

The new thresholds were set by a KGK decision of 13 January 2026, published in Official Gazette No. 33139 on 16 January 2026.

Common misconception: "every large company is in scope"

Size alone does not trigger TSRS. A privately held textile or automotive supplier with 3,000 employees and TRY 10 billion revenue is not in mandatory scope because it does not belong to any listed entity group. It can apply TSRS voluntarily.

Such companies are still affected: in-scope banks need data on financed emissions, listed customers need Scope 3 data from their suppliers, and EU buyers ask for CSRD, CSDDD and CBAM information.

How are the thresholds calculated?

• Group basis: total assets and revenue include subsidiaries (after eliminating intra-group transactions) and the proportional share of associates; employee numbers are two-year averages including subsidiaries.
• Financial statements prepared under Turkish Accounting Standards for the last two periods are used.
• The same two criteria need not be met in both years.
• The entity-group condition also needs two periods: a company that listed in 2025 is not yet in mandatory scope for 2026.
• Exit: the obligation ends if at least two criteria fall below the thresholds for two consecutive periods, or at least two criteria fall 20% or more below the thresholds in a single period.

KGK provides an online calculator, KGK-SÜHA, updated for the new thresholds on 28 January 2026.

Consolidated reporting

• The sustainability reporting entity is the same as the financial reporting entity. A holding company that consolidates subsidiaries must include them, even foreign subsidiaries already reporting under another framework such as ESRS.
• A subsidiary that meets the criteria itself must publish its own report as well.
• A company does not fall into scope merely because its parent or subsidiary is in scope.

Timeline and transition reliefs (2024–2027)

Relief	Basis	2024	2025	2026
Publish later than financial statements (with the half-year interim report or within 9 months of year-end)	Provisional Art. 2, TSRS 1 E4	Yes	Extended (decision of 25.12.2025)	Extended (decision of 19.10.2026)*
Climate-only reporting (TSRS 2)	TSRS 1 E5	Yes	Extended	Extended*
No comparative information	Provisional Art. 1, TSRS 1 E6	First year	For non-climate topics	For non-climate topics in 2027*
No Scope 3 disclosure	Provisional Art. 3	First two years	First two years	Only for entities in their first two years

* The 2026 extension applies to entities that used these reliefs in earlier periods. Entities reporting for the first time in 2026 use the standards' own first-year transition provisions.

October 2026 decisions

Two KGK decisions of 19 October 2026 were published in Official Gazette No. 33408 on 22 October 2026:

1. Decision 46753: the timing relief and the climate-only relief are extended to the 2026 period for entities that used them before; climate-only reporters need not provide comparatives on non-climate topics in 2027.
2. Decision 46754: the provision that made reporting optional for small unlisted banks and non-bank financial institutions (one branch or fewer, or 250 employees or fewer) during their Scope 3 exemption period is repealed for periods beginning on or after 1 January 2026.

A note on Scope 3

Provisional Article 3 limits the Scope 3 exemption to the first two annual periods in which an entity applies TSRS. For entities that started in 2024, that was 2024 and 2025. The 2026 decisions contain no general extension, so entities reporting since 2024 should prepare to disclose Scope 3 in their 2026 reports. Confirm your position with your assurance provider.

TSRS 2 amendments effective from 2027

The ISSB's amendments to the GHG requirements of IFRS S2 were adopted into TSRS 2 (KGK decision of 22 July 2026, Official Gazette No. 33323 of 28 July 2026). They apply to periods beginning on or after 1 January 2027, with early application permitted and disclosed:

• Emissions are measured under the GHG Protocol Corporate Standard unless a jurisdictional authority or the exchange on which the entity is listed requires a different method.
• Requirements for Scope 3 Category 15 (investments / financed emissions) were revised, with additional disclosures.
• The industry classification that commercial banks and insurers use for financed emissions was changed.
• Transition provisions for the first year of application were added.

Assurance

Mandatory TSRS reports are subject to assurance by audit firms authorised by KGK for sustainability assurance. In practice, 2024 and 2025 reports received limited assurance under KGK's Assurance Standard (GDS) 3000 and, for greenhouse gas statements, GDS 3410. Every figure therefore needs a documented source, method and owner.

TSRS vs ESRS vs GRI

	TSRS	ESRS (CSRD)	GRI
Issuer	KGK (Türkiye)	EFRAG / European Commission	Global Reporting Initiative
Basis	IFRS S1 / S2 (ISSB)	EU CSRD	Voluntary global standard
Audience	Investors and lenders	All stakeholders	All stakeholders
Materiality	Financial materiality	Double materiality	Impact materiality
Mandatory?	Yes, for in-scope entities in Türkiye	Yes, for in-scope entities in the EU	Voluntary
Topics	General (TSRS 1) + climate (TSRS 2)	Climate, pollution, water, biodiversity, circularity, workforce, value-chain workers, communities, consumers, business conduct	Full range of economic, environmental and social topics
Assurance	Mandatory (limited)	Mandatory (limited)	Voluntary

Data collected for a GRI report can largely be reused, but TSRS additionally expects the financial effects of risks and scenario analysis, which GRI does not require.

8-step TSRS readiness checklist

1. Run the scope test for the last two periods on a group basis (use KGK-SÜHA).
2. Assign ownership at board level and form a joint finance and sustainability team.
3. Do a gap analysis of TSRS 1 and TSRS 2 requirements against your current data.
4. Identify climate risks and opportunities, physical and transition, over the short, medium and long term.
5. Build a GHG inventory under the GHG Protocol: Scope 1 and 2 first, then the most material Scope 3 categories with supplier data.
6. Run scenario analysis with at least a 1.5°C-aligned and a high-warming scenario.
7. Set targets and metrics, including industry-based metrics.
8. Make your data assurance-ready and engage your assurance provider early.

How STEP4 helps

STEP4 is a sustainability management platform built in Türkiye. It brings together the gap analysis, corporate carbon footprint (GHG Protocol), supplier ESG assessment for value-chain data, and GRI-compliant reporting in one place. Start with the free ESG maturity test or request a demo.

Sources

• KGK, Sustainability page and announcements
• KGK Board Decision 21634 of 27.12.2023 on the scope of TSRS (consolidated text)
• KGK Board Decision 28294 of 16.12.2024 (Official Gazette No. 32756, 18.12.2024)
• KGK Board Decision 38488 of 25.12.2025 on 2025 reliefs (Official Gazette No. 33123, 30.12.2025)
• KGK Board Decision of 13.01.2026 on thresholds (Official Gazette No. 33139, 16.01.2026)
• KGK Board Decision 44275 of 22.07.2026 amending TSRS 2 (Official Gazette No. 33323, 28.07.2026); KGK Announcement 2026-31
• KGK Board Decisions 46753 and 46754 of 19.10.2026 (Official Gazette No. 33408, 22.10.2026)
• ISSB, IFRS S1 and IFRS S2

This guide is for general information and is not legal advice. Check the current text of the KGK decisions and consult your auditor when assessing your scope.