Türkiye's Climate Disclosure Rules: What You Need to Know

Türkiye climate disclosure at a glance

Türkiye's Public Oversight, Accounting and Auditing Standards Authority (KGK) made sustainability reporting under the Türkiye Sustainability Reporting Standards (TSRS 1 and TSRS 2) mandatory for accounting periods beginning on or after 1 January 2024, for listed companies, banks, insurers and other regulated financial institutions that exceed two of three size thresholds, with limited assurance required from the first report. On 16 January 2026 the Authority doubled those thresholds for periods beginning on or after 1 January 2025. Türkiye adopted the ISSB standards with assurance from the first report, and its rules sit alongside the EU Carbon Border Adjustment Mechanism and the domestic emissions trading system created by the Climate Law of July 2025.

How Türkiye got here: two Board decisions and a fast start

Türkiye moved from legal basis to mandatory reporting in eighteen months. Amendments to Article 88 of the Turkish Commercial Code (4 June 2022) and Article 9 of Decree-Law No. 660 (3 November 2022) gave the Authority the power to set sustainability reporting standards, decide who applies them, and publish assurance standards. On 29 December 2023 two decisions appeared in the same Official Gazette: Decision 21632 adopted TSRS 1 and TSRS 2, and Decision 21634 defined the entities in scope, both for periods beginning on or after 1 January 2024. Mandatory assurance followed on 5 September 2024, and the Sustainability Audit Regulation of 17 January 2025 set out how audit firms and auditors are authorised.

What Türkiye's climate disclosure rules require

In-scope entities publish a report titled "TSRS-Compliant Sustainability Report" as part of their general purpose financial reports, prepared under TSRS 1 and TSRS 2 and subject to limited assurance.

• TSRS 1 (General Requirements): the disclosure architecture. Entities report material information about sustainability-related risks and opportunities that are reasonably expected to affect cash flows, access to finance or cost of capital, structured on the four pillars of governance, strategy, risk management, and metrics and targets. A Turkish paragraph 61T, added on 8 May 2025, requires the disclosures to sit in a separately titled report, which can be a self-contained section of an integrated annual report.

• TSRS 2 (Climate-related Disclosures): the climate-specific requirements, including absolute gross Scope 1, Scope 2 and Scope 3 greenhouse gas emissions in tonnes of CO2 equivalent, climate-related transition and physical risks, scenario analysis, and industry-based metrics. The Authority adopted the ISSB's greenhouse gas amendments to TSRS 2 on 28 July 2026, effective for periods beginning on or after 1 January 2027, covering Scope 3 Category 15 financed emissions, the sector classification used by banks and insurers, and the option for a competent authority or exchange to require a different measurement method.

• The Greenhouse Gas Protocol as the measurement standard: TSRS 2 paragraph 29(a)(ii) requires emissions to be measured in accordance with the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard (2004), with the same one-period carry-over relief as IFRS S2 for entities that used a different method in the prior year.

Reports are consolidated at the level of the entity that prepares the financial statements, so a Turkish parent includes subsidiaries, joint ventures and associates wherever they operate, including subsidiaries that already report under EU rules. A subsidiary that meets the thresholds on its own also publishes its own report.

Who is in scope

An entity is in scope when it belongs to one of the regulated categories in Decision 21634 and exceeds two of three size thresholds in two consecutive reporting periods, assessed on financial statements prepared under Turkish Accounting Standards.

The regulated categories are companies supervised by the Capital Markets Board, entities supervised by the Banking Regulation and Supervision Agency, insurance and pension companies, and precious metals institutions operating on Borsa Istanbul markets. Every other company can apply the standards voluntarily.

Thresholds by reporting period

• Financial year 2024: total assets TRY 500 million, annual net sales revenue TRY 1 billion, 250 employees.

• Financial year 2025 onward: total assets TRY 1 billion, annual net sales revenue TRY 2 billion, 500 employees, set by Decision 39092 of 13 January 2026.

An entity enters scope in the period after two consecutive periods above two thresholds (the two can differ between periods), and leaves after two consecutive periods below two thresholds, or one period at least 20 per cent below two. Assets, revenue and employees are counted with subsidiaries in full and associates in proportion to the shareholding, including operations outside Türkiye. The Authority's KGK-SÜHA calculation tool, released on 7 November 2025, runs the test.

Listed companies and capital market institutions

Companies whose shares trade on Borsa Istanbul markets, excluding the Close Monitoring Market and the Venture Capital Market, plus investment firms, collective investment schemes, mortgage finance institutions, central clearing houses, central securities depositories and trade repositories. Private issuers of non-equity instruments left mandatory scope on 18 December 2024, and portfolio management companies on 14 August 2025.

Banks and non-bank financial institutions

Banks report without a threshold test, unless they sit within the Savings Deposit Insurance Fund. Rating agencies, financial holding companies, leasing, factoring, financing, asset management and savings finance companies, and qualified shareholders of banks and financial holdings, report when they exceed the thresholds. Unlisted banks and non-bank financial institutions with at most one branch or at most 250 employees at the prior year-end report voluntarily during the periods in which the Scope 3 relief applies.

Insurance, reinsurance and pension companies

Companies operating under the Insurance Law and the Private Pension Law report when they exceed the thresholds, with revenue measured as the sum of non-life, life and pension technical income.

Supply-chain reach: every reporter discloses Scope 3 from its third reporting period, and Turkish banks and insurers disclose financed emissions under Category 15. Suppliers, borrowers and investee companies of Turkish listed groups and financial institutions, in Türkiye and abroad, will receive emissions data requests from 2026 onward whatever their own home rules require.

Key dates and milestones

The first-year reliefs let an entity publish its first report after its financial statements, alongside the half-year interim report or within nine months of year-end, and limit it to climate-related information. Decision 38488 of 25 December 2025 extended the TSRS 1 reliefs in paragraphs E4, E5 and E6(b) by one year for entities that first reported on 2024, so those entities can use them again for financial year 2025. From the third period, sustainability disclosures are published at the same time as the financial statements.

Why this matters beyond Türkiye

1. Supply-chain ripple across Europe, the Middle East and Central Asia. Turkish listed groups in steel, cement, automotive, textiles, food and white goods consolidate subsidiaries across the region, and their Scope 3 obligations from financial year 2026 become data requests for suppliers in Germany, Italy, the Gulf, the Balkans and Central Asia. Turkish banks and insurers add financed emissions requests to borrowers and investees under Category 15.

2. Convergence with the ISSB baseline and the EU. TSRS 1 and TSRS 2 keep the ISSB text, so a group with entities in Türkiye, the EU, the UK, Singapore or Australia can build one IFRS S2-aligned inventory and reuse it. Turkish exporters into the EU customs union also face the Carbon Border Adjustment Mechanism, in its definitive period since 1 January 2026, which prices embedded emissions in steel, aluminium, cement, fertilisers, electricity and hydrogen at the EU border. The same Scope 1 and Scope 2 data serves both.

3. A domestic carbon price is coming. The Climate Law (No. 7552), published on 9 July 2025, establishes a Turkish emissions trading system with a pilot phase before full operation. Installations that will surrender allowances need verified emissions data, and the TSRS inventory is the starting point.

How companies should prepare

Entities that first reported on 2024 are nine months into financial year 2026, their first Scope 3 period, with an assurance provider reviewing the numbers.

• Establish your greenhouse gas inventory on the GHG Protocol. Scope 1 and Scope 2 have been reported and assured since the 2024 cycle. The gap is Scope 3 by category across every consolidated subsidiary, in Türkiye and abroad, and the two-period relief was the preparation window.

• Map your value-chain exposure to Turkish reporters. If your customers are Borsa Istanbul-listed groups, or your lenders and insurers are Turkish financial institutions, their Scope 3 and financed emissions numbers include you. Knowing which of them report, and from which year, tells you when the data requests arrive.

• Build assurance-ready processes early. Limited assurance has applied from the first report, and the audit standard tightens when SGDS 5000 takes effect. Methodology documentation, source-data traceability and review controls need to be in place during measurement, so that every figure in the TSRS-Compliant Sustainability Report answers the auditor's question: where did this number come from?

• Build on the frameworks you already use. The four pillars of governance, strategy, risk management, and metrics and targets carry directly from existing TCFD, CDP and Borsa Istanbul sustainability reporting into TSRS 2. Subsidiaries of EU groups can reuse ESRS E1 climate data. The new work is Scope 3, industry-based metrics and scenario analysis.

Your first climate audit

Preparing for your next limited assurance engagement under TSRS 2? Download Your First Climate Audit: A Practical Guide for a step-by-step walkthrough of what assurance providers ask for and how to get your data ready.

How Terrascope can help

Terrascope's AI-powered platform helps companies operating in Türkiye and across Europe move from baseline emissions data to audit-ready disclosures, including BBR VT, the Swiss post-tensioning and structural systems manufacturer that screened 100 per cent of its suppliers and calculated supplier-specific emissions for 80 per cent of its imported goods ahead of the EU Carbon Border Adjustment Mechanism deadline.

• Scope 1, 2, and 3 emissions measurement (Corporate carbon footprinting). Integrations pull emissions data from your source systems monthly, so your inventory stays current across every consolidated subsidiary and every Scope 3 category you need before the third reporting period.

• Audit-ready reporting. Audit Trail makes every figure traceable from data entry to disclosure, with assurance-provider access built in, so your KGK-authorised auditor works from traceable evidence.

• Supply-chain intelligence (Supplier engagement). Analytics shows you where your Scope 3 hotspots sit, so the relief period becomes reduction planning time and your CBAM and TSRS data come from one inventory.

• Multi-framework alignment (Climate reporting). ISSB Reporting drafts your TSRS 1 and TSRS 2 disclosures from your measured data, reviewed by your team, ready for the TSRS-Compliant Sustainability Report.

Frequently asked questions

Speak to an expert

Are you ready to get ahead of Türkiye's TSRS 2 requirements? Speak to a Terrascope expert and see how we help companies move from baseline emissions data to audit-ready disclosures.