TSRS: Türkiye's sustainability reporting standards

Your company falls under TSRS if, for an accounting period beginning on or after 1 January 2025, it exceeds at least two of three size thresholds — total assets of TRY 1 billion, annual net sales revenue of TRY 2 billion, or 500 employees — the values set by a KGK Board decision published in the Resmî Gazete on 16 January 2026 (No. 33139). TSRS, Türkiye's sustainability reporting standards, is the public-oversight regulator KGK's adoption of the ISSB's IFRS S1 and S2, and its climate standard — TSRS 2 — requires an in-scope company to disclose its absolute gross Scope 1, 2 and 3 greenhouse-gas emissions in tonnes of CO₂ equivalent. Below is who is caught, from when, and exactly what has to be disclosed.

What is TSRS?

TSRS is Türkiye's set of sustainability reporting standards, created by the Kamu Gözetimi, Muhasebe ve Denetim Standartları Kurumu (KGK) by adopting the standards of the International Sustainability Standards Board (ISSB). It comes in two parts: TSRS 1, on the general requirements for disclosing sustainability-related financial information, is Türkiye's counterpart of IFRS S1; TSRS 2, on climate-related disclosures, is the counterpart of IFRS S2. Both were published in the Resmî Gazete of 29 December 2023 (No. 32414), per KGK's announcement. KGK's authority to set them comes from Article 88 of the Turkish Commercial Code (Law No. 6102), as amended by Law No. 7408 of 2 June 2022.

"Söz konusu yetkiye istinaden Kurumumuz, Türkiye Sürdürülebilirlik Raporlama Standartlarının uluslararası dayanağı olarak … Uluslararası Sürdürülebilirlik Standartları Kurulu (ISSB) tarafından yayımlanan uluslararası standartları benimseme kararı almıştır."

— KGK (Kamu Gözetimi, Muhasebe ve Denetim Standartları Kurumu). Announcement PDF

In English, KGK states that, acting on that authority, it decided to adopt — as the international basis of the Turkish Sustainability Reporting Standards — the standards published by the ISSB within the IFRS Foundation. So a company that already understands IFRS S1 and S2 is reading the same substance, issued in Turkish by the Turkish regulator.

Who has to report under TSRS?

A company is generally in scope if, for an accounting period beginning on or after 1 January 2025, it exceeds at least two of these three thresholds: total assets of TRY 1 billion, annual net sales revenue of TRY 2 billion, and 500 employees. These are not three independent triggers — crossing a single one does not, on its own, put you in scope. The figures come from the KGK Board decision dated 13 January 2026, published in the Resmî Gazete of 16 January 2026 (No. 33139).

These figures replaced the original 2023 thresholds — this is the paragraph to read twice. When TSRS scope was first set in December 2023, the size thresholds were lower: total assets of TRY 500 million, annual net sales revenue of TRY 1 billion, and 250 employees. The 16 January 2026 decision raised them to TRY 1 billion / TRY 2 billion / 500 employees and made them apply from accounting periods beginning on or after 1 January 2025. If you have read an older guide that cites TRY 500 million, TRY 1 billion or 250 employees, those numbers are superseded — use the current ones.

"Aktif toplamı 1 Milyar Türk Lirası, - Yıllık net satış hasılatı 2 Milyar Türk Lirası, - Çalışan sayısı 500 kişi … bu Kararın 1/1/2025 tarihinde veya sonrasında başlayan hesap dönemlerinde uygulanmasına …"

— KGK Kurul Kararı, Resmî Gazete 16/01/2026, No. 33139. Decision PDF

In English, KGK sets the criteria at total assets of TRY 1 billion, annual net sales revenue of TRY 2 billion, and 500 employees, and directs that the decision apply to accounting periods beginning on or after 1 January 2025.

When did TSRS first apply?

The standards took effect for accounting periods beginning on or after 1 January 2024, making FY2024 the first mandatory reporting period for entities in scope. That is set out in Madde 5 of the KGK scope decision of 29 December 2023 (Resmî Gazete No. 32414), and TSRS 2 itself carries the same effective date, with early application permitted.

Keep two dates apart. The standard's effective date is FY2024. But who is in scope was reset later: the size thresholds that decide which companies must report were revised on 16 January 2026 and apply from accounting periods beginning on or after 1 January 2025. So the effective date of the standard and the current scope test point at different years — read the current thresholds against your FY2025 numbers.

What does TSRS 2 make me disclose about my emissions?

TSRS 2 paragraph 29(a) requires you to disclose your absolute gross greenhouse-gas emissions for the reporting period, in metric tonnes of CO₂ equivalent, classified separately as Scope 1, Scope 2 and Scope 3, per the TSRS 2 text (KGK).

"Raporlama dönemi boyunca üretilen, metrik ton CO2 eşdeğeri olarak ifade edilen … mutlak brüt sera gazı emisyonlarını açıklar: (1) Kapsam 1 …, (2) Kapsam 2 … ve (3) Kapsam 3 sera gazı emisyonları."

— TSRS 2 İklimle İlgili Açıklamalar (KGK), ¶29(a)(i). TSRS 2 PDF

In English, the entity discloses its absolute gross greenhouse-gas emissions produced during the reporting period, expressed in metric tonnes of CO₂ equivalent, classified as (1) Scope 1, (2) Scope 2 and (3) Scope 3 emissions.

Three details matter for how you measure and split those numbers, all from the same TSRS 2 text:

• Measurement method. You measure emissions in accordance with the GHG Protocol Corporate Accounting and Reporting Standard (2004), unless a competent authority or the exchange you are listed on requires a different method (paragraph 29(a)(ii)). In your first TSRS period you may keep a method you were using immediately beforehand.
• Scope 2. For Scope 2 you disclose the location-based figure and provide information about the contractual instruments needed to understand it (paragraph 29(a)(v)) — a separate market-based figure is not mandated.
• Scope 3 categories. You disclose which categories are included in your Scope 3 measurement, using the categories defined in the GHG Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard (2011). Note that this 2011 standard is itself under revision, so the referenced version may change.

Do I have to report Scope 3 straight away?

No. A transitional provision — Geçici Madde 3 of the KGK scope decision — exempts you from disclosing Scope 3 greenhouse-gas emissions in the first two annual reporting periods in which you apply TSRS.

"GEÇİCİ MADDE 3 – İşletmelerin, uygulama kapsamı çerçevesinde TSRS'leri uyguladıkları ilk iki yıllık raporlama dönemlerinde Kapsam 3 sera gazı emisyonlarını açıklamaları zorunlu değildir."

— KGK, TSRS Uygulama Kapsamına İlişkin Kurul Kararı. Scope-decision PDF

In English: entities are not required to disclose their Scope 3 emissions in the first two annual reporting periods in which they apply TSRS. Scope 1 and Scope 2 are required from the first period; only Scope 3 gets the two-year runway.

Do I need comparative figures in year one?

No. Under Geçici Madde 1 of the same KGK scope decision, entities are not required to present comparative (prior-period) information in the first reporting period in which they apply TSRS.

"GEÇİCİ MADDE 1 – İşletmelerin TSRS'leri uyguladığı ilk raporlama döneminde karşılaştırmalı bilgileri sunması zorunlu değildir."

— KGK, TSRS Uygulama Kapsamına İlişkin Kurul Kararı. Scope-decision PDF

In English: entities need not present comparative information in their first TSRS reporting period. In that first year you report the current period alone.

What else does TSRS 2 require, beyond the numbers?

Beyond the emissions figures, TSRS 2 asks for forward-looking, narrative disclosures. Two are worth flagging, both from the TSRS 2 text: paragraph 22 requires you to use climate-related scenario analysis — with an approach commensurate with your circumstances — to assess your climate resilience; and paragraph 14(a)(iv) requires you to disclose any climate-related transition plan you have, including the key assumptions used to develop it and the dependencies it relies on. These are qualitative, but they are not optional for an entity in scope.

Does a TSRS report have to be assured (audited)?

There is a regulation that governs sustainability assurance in Türkiye, but the primary texts set no fixed date on which external assurance of a TSRS report becomes mandatory. The Sürdürülebilirlik Denetimi Yönetmeliği (Resmî Gazete No. 32785, 17 January 2025) sets out the procedures for sustainability assurance and which independent audit firms and auditors may perform it, covering assurance done under legislation or voluntarily. So the machinery — who may assure a report, and how — exists. What these texts do not do is name a date from which assurance of a TSRS report is compulsory. Treat assurance as a live and coming requirement to plan for, not one with a published start date.

What is the difference between Scope 1, 2 and 3?

Scope 1 is direct emissions from sources your company owns or controls; Scope 2 is the indirect emissions from the energy you buy; Scope 3 is all other indirect emissions across your value chain. The definitions come from the GHG Protocol Corporate Accounting and Reporting Standard (2004 revised edition), which TSRS 2 references and of which a further revision is in development.

The GHG Protocol defines Scope 1 as direct emissions that "occur from sources that are owned or controlled by the company" — for example, combustion in owned or controlled boilers, furnaces and vehicles. For Scope 2, TSRS 2 is what governs you: it asks for the location-based figure plus information on the contractual instruments, as set out above. Scope 3 the GHG Protocol calls "an optional reporting category" covering all other indirect emissions that are a consequence of your activities but occur from sources you do not own or control. "Optional" there refers only to the voluntary GHG Protocol framework — under TSRS 2 (and, in the EU, under CSRD/ESRS E1, and in California under SB-253) Scope 3 disclosure is mandatory, subject to the two-year relief above.

One guarantee is worth knowing: the GHG Protocol says companies "shall separately account for and report on scopes 1 and 2 at a minimum," and defines Scopes 1 and 2 so that "two or more companies will not account for emissions in the same scope" — which avoids double counting between companies for those two scopes.

How does TSRS relate to CSRD, ESRS and CBAM?

TSRS and the EU's CSRD/ESRS are separate regimes built on shared foundations. TSRS is Türkiye's adoption of the ISSB's global baseline (IFRS S1 and S2); the EU's Corporate Sustainability Reporting Directive and its European Sustainability Reporting Standards (ESRS) are the EU's own, EU-specific framework. They are not the same rulebook, but they point the same way on emissions: Scope 3 disclosure is mandatory under TSRS 2 as well as under the EU's ESRS E1 and California's SB-253, per the GHG Protocol Corporate Standard.

CBAM is a different instrument again — the EU's carbon border adjustment mechanism, a charge tied to the carbon embedded in certain imported goods, not a company reporting standard. If you export steel, aluminium, cement or fertilisers to the EU, it is a separate obligation from TSRS reporting; we cover it in CBAM for Turkish exporters.

How do I actually produce the Scope 1, 2 and 3 figures?

You produce them from an emissions ledger: every activity is recorded against an emission factor, the CO₂e is posted and totalled by scope and reporting period. Nakitte Carbon's carbon ledger records each activity against an emission factor, posts the resulting CO₂e as quantity × factor through a review-and-approval step, and totals it by scope and period — which is the raw material of a paragraph 29(a) disclosure.

The product available today is Carbon Accounting — the ledger that produces the Scope 1, 2 and 3 numbers TSRS 2 asks for.

Last reviewed against its primary sources on 9 July 2026. Every figure on this page is quoted from the regulator, standard-setter or statistical office named beside it. Regulatory thresholds and deadlines change — check the linked source before you rely on it.