Does every company exceeding the 2026 thresholds fall within TSRS scope?

No. First it is determined whether the company is one of the entity types listed in the POA Board Decision. For entities subject to the thresholds, it is then assessed whether at least two of the criteria — TL 1 billion total assets, TL 2 billion annual net sales revenue and 500 employees — have been exceeded in two consecutive reporting periods. Banks are also subject to special scope provisions.

Is it mandatory to disclose Scope 3 emissions from the first year?

Under the current POA transition provision, entities are not required to disclose Scope 3 greenhouse gas emissions in the first two annual reporting periods in which they apply TSRS. Nevertheless, it is beneficial to build the data infrastructure early for subsequent periods.

How long does the TSRS advisory process take?

The duration varies depending on your company's size, the number of subsidiaries and the maturity of your existing data infrastructure. We provide a tailored timeline after the scope assessment.

How is the advisory cost determined?

The cost is customised based on the scope of the project (number of locations, number of subsidiaries, current state of data infrastructure). We start with a free scope assessment to provide an exact quote.

Should we first clarify whether our company is within TSRS scope?

Yes, the first step is always the scope assessment. This assessment also determines the scope of the following steps (data collection, materiality analysis, etc.).

We are already preparing a GRI report; do we start from scratch for TSRS?

It is not always necessary to start from scratch. Your existing GRI data inventory may contain data usable for TSRS purposes; however, TSRS's investor-focused materiality approach, financial linkages, climate disclosures and assurance evidence must be separately assessed.

Which independent auditor will conduct the assurance audit?

The assurance audit must be conducted by an auditor or audit firm authorised in the field of sustainability in accordance with POA regulations. EUROPECARBON supports pre-audit preparation, the evidence file and auditor coordination; the independent auditor forms the assurance opinion.

We are below the threshold; do we still need advisory support?

Being below the thresholds alone does not mean you are outside TSRS scope. First it should be checked whether the company is one of the entity types listed in the POA Board Decision and whether special scope provisions apply. For entities subject to the thresholds, not meeting the thresholds may result in exclusion from mandatory scope; however, banks are subject to a special mandatory scope provision independent of the thresholds, except for the exemption within the SDIF. Entities outside mandatory scope may also carry out voluntary TSRS work due to customer, financing, export or group reporting needs.

We have multiple locations/factories, how does the process work?

We establish a separate data collection plan for each location and clarify, based on your company structure, whether a consolidated or solo assessment applies; we plan site visits accordingly.

Can we only take the scope assessment and do the rest ourselves?

Yes, we offer our services modularly — you can take just the scope and threshold assessment and progress data collection and the report draft with your in-house team.

If we are also within CBAM scope, do we proceed separately or together?

It is generally more efficient to plan common data points together. However, the purposes, system boundaries and calculation rules of TSRS and CBAM are not the same; therefore, while common source data is managed in a single infrastructure as much as possible, the calculation and reporting requirements of both regulations must be checked separately.

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TSRS Advisory: End-to-End Compliance from Scope Analysis to Assurance Audit

150+ project experience in TSRS scope analysis, data infrastructure setup and assurance audit preparation. Let's plan your company's TSRS compliance together.

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Clarify whether your company falls within the scope of TSRS through the thresholds and entity-type conditions updated by the POA's 13 January 2026 decision; manage the preparation process with an experienced team. With the experience we have gained from more than 150 sustainability and carbon consultancy projects, we stand by you at every stage of your TSRS process, from scope determination to assurance audit preparation.

What Is TSRS? In Brief

TSRS (Turkish Sustainability Reporting Standards) are sustainability-related financial reporting standards issued by the Public Oversight, Accounting and Auditing Standards Authority (POA/KGK) and applied to accounting periods beginning on or after 1 January 2024. TSRS 1 and TSRS 2 make up the Turkish standard set aligned with IFRS S1 and IFRS S2 issued by the ISSB. The POA Board Decision dated 13 January 2026, published in the Official Gazette dated 16 January 2026 and numbered 33139, updated the thresholds to total assets of TL 1 billion, annual net sales revenue of TL 2 billion and 500 employees. The new thresholds apply to accounting periods beginning on or after 1 January 2025. The scope test is two-staged: it is not enough for an entity merely to exceed the thresholds. First, it is determined whether the entity is one of the entity types listed in the POA's Board Decision on the Scope of TSRS Application; for entities subject to the thresholds, it is then assessed whether at least two of the three criteria have been exceeded in two consecutive reporting periods. For banks, the Board Decision also contains special scope provisions independent of the thresholds. Mandatory assurance audit for sustainability reports within the scope of TSRS was put into effect by the POA Board Decision dated 5 September 2024, and the current mandatory application is carried out under a limited assurance approach. Until the regulatory process for SGDS 5000 — General Requirements for Sustainability Assurance Engagements is completed and the related implementation provisions enter into force, GDS 3000 and, where relevant for greenhouse gas statements, GDS 3410, are applied within the framework of current POA regulations. You can find all the details of TSRS — the threshold calculation method, exemptions, and the difference with CSRD — in our article "What Is TSRS? Threshold Values and Scope Guide." Here we focus on how we help you in the TSRS compliance process.

Why TSRS May Be Worrying You

Scope ambiguity — thresholds were updated in 2026, but a proper assessment is not just about looking at figures. First it should be examined whether your company is one of the entity types listed in the POA Board Decision, and then, if you are subject to the thresholds, whether at least two of the three criteria have been exceeded in two consecutive reporting periods; Compliance and reputation risk — failing to fulfil TSRS obligations fully or correctly can create risks in terms of regulatory compliance, sustainability assurance audit, investor communication and corporate reputation. In addition, large customers and financing providers may request sustainability data for their own information needs; Data collection complexity — the data owners of Scope 1-2 emissions, energy data and other metrics material to your business may sit in different departments. Although there is a transition exemption for Scope 3 in the first two annual reporting periods in which you apply TSRS, building the supply-chain data infrastructure early for later periods provides an important preparation advantage; Unpreparedness for the assurance audit — under the POA decision dated 5 September 2024, sustainability reports are now subject to independent assurance audit. Entering the process without knowing exactly what the auditor will check regarding data source, internal control structure and methodological consistency carries the risk of finding no opportunity to correct the report once it is completed. If any of these questions sound familiar, an initial meeting starting with a scope assessment is often enough to provide the necessary clarity. You can find detailed information on how the thresholds changed and the scope criteria in our article "What Is TSRS? Threshold Values and Scope Guide."

Why Act Now?

TSRS is tied to a concrete reporting and assurance timetable. The threshold decision dated 13 January 2026 entered into force to apply to accounting periods beginning on or after 1 January 2025. The POA also updated the POA-SÜHA scope calculation tool according to the new criteria on 28 January 2026. Companies that start early can clarify data owners, calculation methods, control points and audit evidence before writing the report. Preparation left to the last minute can make it harder to retrospectively verify data and complete missing evidence. On the assurance side, we base our work on the rules currently in force rather than speculation: until the regulatory process for SGDS 5000 — General Requirements for Sustainability Assurance Engagements is completed and the related implementation provisions enter into force, GDS 3000 and, where relevant for greenhouse gas statements, GDS 3410, are applied within the framework of current POA regulations. The current mandatory assurance approach is at the limited assurance level. As financing providers' sustainability data requests may vary by product and institution, a TSRS report should not be presented as an automatic loan condition.

Our Service Scope

1. Scope and Threshold Assessment — We first determine whether your company is one of the entity types listed in the POA Board Decision; if you are subject to the thresholds, we assess total assets, annual net sales revenue and employee numbers against the current thresholds (TL 1 billion, TL 2 billion, 500 employees) and the two-consecutive-reporting-period rule. In group structures, we also include the effects of subsidiaries and associates in the scope calculation according to the Procedures and Principles. 2. TSRS Materiality and Risk/Opportunity Analysis — Following the TSRS 1 approach, we identify sustainability-related risks and opportunities that could reasonably be expected to affect your company's cash flows, access to finance or cost of capital in the short, medium or long term; we assess material information that could affect the decisions of primary financial report users. A double materiality analysis is additionally conducted where needed for companies within the scope of CSRD/ESRS. 3. Data Collection Infrastructure Setup — We build a repeatable system defining data ownership, source documents, calculation methods and control points for energy consumption, Scope 1-2 emissions and other indicators material to your business. We take into account the transition exemption in the first two TSRS reporting periods for Scope 3; we plan the supply-chain data infrastructure for the following period's preparation. 4. TSRS 1 / TSRS 2 Compliant Report Draft — We structure the collected data in line with the disclosure requirements of TSRS 1 and TSRS 2, around the core content areas of Governance, Strategy, Risk Management and Metrics and Targets. As the POA does not mandate a specific single-page layout or file format, we design the presentation to fit your company's reporting architecture. 5. Assurance Audit Preparation — We help you prepare for the limited assurance audit conducted under GDS 3000/3410 standards through early contact with the independent auditor, data-source documentation, clarification of internal control points and pilot internal audit support. 6. CBAM Integration (For Exporting Producers) — For activities within the scope of CBAM such as cement, iron-steel, aluminium and fertilizer, we identify common data points between TSRS and CBAM. Since system boundaries and calculation rules are not identical, we pool data from a single source wherever possible to reduce duplicate workload. You can review our "CBAM / CBAM Reporting" page for the sectors within the scope of CBAM and our reporting service.

Our Working Process

Preliminary Meeting and Scope Screening — We assess your current situation, sector and financial size. This meeting is free of charge and typically takes 30-45 minutes; at the end, we share an initial opinion on whether you are in scope. Detailed Scope Report — Together we carry out the entity-type test under the Board Decision and, if necessary, the two-consecutive-reporting-period analysis over the three criteria, and present the basis of the calculation and the proposed roadmap in writing. Data Collection and TSRS Materiality Analysis — We establish the data foundation of the report through site visits, departmental interviews and review of existing data systems; we assess sustainability-related risks and opportunities and the related material information according to the TSRS approach. Report Draft and Internal Review — We prepare the draft in accordance with the disclosure requirements of TSRS 1 and TSRS 2, carry out consistency checks in the areas of Governance, Strategy, Risk Management and Metrics and Targets, and complete the necessary corrections. Handover to Assurance Audit — We coordinate with your independent auditor, prepare in advance the documents the auditor will first request, and provide support throughout the process.

What Will You Have at the End of the Process?

At the end of the advisory process, you are left with concrete, usable outputs — not just an advisory report: Written scope assessment report — a document that can be shared with management and the auditor, showing the entity-type test, the threshold calculation where necessary, the two-consecutive-period assessment and the effect of group companies on the calculation; TSRS materiality and risk/opportunity assessment — a study showing, with justifications, the sustainability-related risks and opportunities that could affect your company's expectations and which information is material; Repeatable data collection template — a data collection system that can be distributed across departments and reused the following year, not a one-off spreadsheet; TSRS 1 / TSRS 2 compliant report draft — a document aligned with the disclosure requirements and the four core content areas, prepared for the assurance audit; Assurance audit readiness checklist — a documentation set enabling you to answer your auditor's questions in advance.

Why EUROPECARBON?

TSRS preparation brings together multiple disciplines within the same project — scope legislation, assessment of sustainability-related risks and opportunities, data infrastructure, reporting and assurance preparation. EUROPECARBON aims to coordinate these workflows in a single roadmap to prevent data ownership and reporting requirements from becoming disconnected. 150+ Projects — our number of completed projects in sustainability reporting and carbon consultancy. 15+ Years of Experience — our total experience in the sector. CBAM + TSRS Integrated Expertise — we manage common data points within a single project architecture while separately controlling the system boundaries and calculation rules of the two regulations. Third-Party Verification — we strengthen the credibility of your report with our carbon and sustainability data verification services. Training Partnership — through our partnership with MegaDemi, we can offer dedicated TSRS/sustainability training to your team.

Who Is This Suitable For?

Our advisory service is designed especially for companies with the following profile: Companies on the POA scope list and near the thresholds — companies that are one of the entity types listed in the Board Decision and whose total assets, annual net sales revenue or employee count are approaching the current thresholds. Exporting producers intersecting with CBAM — companies producing products within the scope of CBAM, such as cement, iron-steel, aluminium and fertilizer, that want to manage common data points with the TSRS data infrastructure. Existing GRI/voluntary reporters — companies that have prepared voluntary reports according to GRI standards for years but want to clarify how to integrate TSRS's additional requirements (financial materiality, assurance audit). Holding and group companies — company groups with multiple subsidiaries where it is unclear whether consolidated or solo assessment applies. Companies seeking financing — companies applying for a green loan or sustainability-linked loan that do not yet have the basic ESG data requested by banks ready.

What Is Discussed in the Free Initial Meeting?

In the initial meeting we address scope in two stages: first, whether your company is one of the entity types listed in the POA Board Decision, and then, if you are subject to the thresholds, we assess the trajectory of total assets, annual net sales revenue and employee count over the relevant two reporting periods. Group structure, subsidiaries and associates, as well as existing GRI or other voluntary reporting data, are also discussed in this meeting. At the end of the meeting, you receive a clear direction — either "you are in scope, let's proceed with these steps" or "you are not currently in scope, but we still recommend an assessment for the following commercial reasons" — you do not leave the meeting with uncertainty.

In-House Team or External Advisor? Why We Recommend a Hybrid Model

The advantage of preparing the TSRS report entirely with an in-house team is that corporate knowledge does not leave the company and process ownership stays in-house; the disadvantage is the lack of experience given how relatively new the TSRS standard is, and possible methodological errors in preparing for the assurance audit. That's why in practice the model that yields the healthiest result is a hybrid structure: your in-house team takes on data ownership and inter-departmental coordination, while we provide support in methodology, TSRS materiality and sustainability-related risk/opportunity analysis, and assurance audit preparation. Especially in the first reporting cycle, this hybrid model shortens the learning curve and increases methodological credibility with the auditor. Instead of building a team from scratch to learn TSRS, we combine your existing team's knowledge with our process experience.

Common Mistakes in the TSRS Process (And How We Prevent Them)

With the experience gained from 150+ projects, the recurring mistakes among companies newly entering the scope are largely preventable. Our advisory process specifically targets these five points: Clarifying company boundaries too late — starting to collect data before determining which subsidiary is included in consolidation leads to data having to be collected from scratch. We clarify company boundaries right from the start during scope determination. Skipping the TSRS materiality assessment — starting to collect data without assessing the possible effect of sustainability-related risks and opportunities on the company's expectations, and which information could affect primary users' decisions, can pull the report away from its focus. Confusing the Scope 3 transition exemption with lack of preparation — the existence of a transition exemption for Scope 3 disclosure in the first two TSRS reporting periods does not mean the data infrastructure should be postponed. We plan data owners and supplier data flows early for the following period. Making contact with the auditor too late — if expectations are learned only after the report is completed, there is no time left for correction. Our assurance audit preparation step requires early contact with the auditor. Viewing the report only as a compliance document — a report that meets the legal obligation but produces no commercial value ignores the demands of investors and large customers. We aim for your report to both pass the audit and become a commercial asset.

Sector-Specific Experience

With the sectoral experience gained from our 150+ projects, we know how TSRS preparation differs across manufacturing sectors such as chemicals, textiles, food, cement and iron-steel. Since TSRS 2 is climate-focused, data collection complexity varies significantly in energy-intensive sectors. TSRS 2 focuses on climate-related disclosures, but it does not impose a single, fixed list of metrics for every sector. Sector-specific risks, opportunities and metrics differ according to the operational structure. The IFRS Foundation's sector-based SASB Standards and related sector guides are important resources to consider when determining disclosure topics relevant to a business's activities. In chemical, textile, food and other manufacturing sectors, the significance of energy, water, process emissions or supply-chain indicators is determined according to the company's own circumstances and the TSRS materiality assessment. In CBAM-covered activities such as cement, iron-steel and aluminium, some emissions data may come from common sources for both reporting processes; nevertheless, the system boundaries and calculation rules of TSRS and CBAM must be checked separately. You can review our "carbon footprint consultancy," "GRI sustainability reporting" and "CBAM / CBAM reporting" pages for related services.

Official Sources and Up-to-Date Guides

We check the scope, threshold, report structure and assurance disclosures on this page against the following primary sources. As legislation may change, current POA regulations should be relied on when making scope decisions. POA — Sustainability Legal Regulations: the official list of Board Decisions on TSRS application scope, the 2026 threshold decision and assurance. 16 January 2026 — POA Board Decision on Redetermining TSRS Threshold Values: sets thresholds of TL 1 billion total assets, TL 2 billion annual net sales revenue and 500 employees; these thresholds apply to accounting periods beginning on or after 1 January 2025. POA — Sustainability FAQ: official explanations on scope logic, the report's four core content areas and the Scope 3 transition exemption (note: some old threshold examples on the FAQ page may not be updated; the 16 January 2026 threshold decision should be relied on for current amounts). POA — E-Services / POA-SÜHA: access to the official calculation tool that helps companies calculate TSRS scope. POA — Turkish Auditing Standards 2026 Set: current assurance standards including GDS 3000 and GDS 3410. POA — SGDS 5000 Draft Regulation Announcement: the POA's official announcement on the regulatory process for "SGDS 5000 — General Requirements for Sustainability Assurance Engagements." IFRS Foundation — IFRS S1: the core source for sustainability-related risks and opportunities and the financial materiality approach. European Commission — CBAM Sectors: the official list of current CBAM sectors. Related EUROPECARBON guides: TSRS reporting calendar, TSRS limited assurance audit, TSRS-CSRD difference, and the 2026 sustainability reporting guide.

How we work

1Preliminary meeting and scope screening: assessing your current situation, sector and financial size (free, 30-45 minutes)
2Detailed scope report: entity-type test and, where necessary, two-consecutive-reporting-period analysis over the three criteria
3Data collection and TSRS materiality analysis: site visits, departmental interviews and review of existing data systems
4Report draft and internal review: drafting per TSRS 1/TSRS 2 disclosure requirements and consistency checks
5Handover to assurance audit: coordination with the independent auditor and preparation of required documents