Pursuant to the decision of the Public Oversight, Accounting and Auditing Standards Authority (“KGK”) published in the Official Gazette on 16 January 2026, the threshold values determining the scope of application of the Turkish Sustainability Reporting Standards (“TSRS”) have been significantly increased.
The substantial increase in the threshold values has effectively narrowed the scope of the sustainability reporting obligation, and a significant portion of medium‑sized undertakings has likely fallen outside the remit of the TSRS. This amendment may be viewed also as a response to the fact that the previous thresholds had become inadequate in reflecting the real economic conditions due to high inflation, thereby necessitating a recalibration aligned with macroeconomic realities and the regulator’s need to adjust the framework to a more meaningful economic level.
The TSRS constitutes a regulatory framework that aims to ensure the standardized reporting of non‑financial information by undertakings in the fields of environmental, social and governance (ESG). Whether an undertaking falls within the scope of TSRS is determined based on whether at least two of the financial and structural criteria set by the KGK are met, taking into account the undertaking’s Turkey Financial Reporting Standards financial statements and employee numbers for the preceding two financial years.
Under the Board Decision dated 13 January 2026 and numbered 75935942‑050.01.04‑[01/39092], the criteria for determining whether an undertaking falls within the scope of the TSRS have been increased as follows:
- Total assets: TRY 1 billion
- Annual net sales revenue: TRY 2 billion
- Number of employees: 500
These new thresholds will apply to financial reporting periods beginning on or after 1 January 2025. Under the KGK’s previous decision, the thresholds applicable to the 2024 reporting period were TRY 500 million in total assets, TRY 1 billion in annual net sales revenue, and 250 employees. Accordingly, the 2026 Board Decision updates these thresholds upward, thereby limiting the TSRS reporting obligation to larger‑scale undertakings. Scope assessments will continue to be carried out in line with the TSRS methodology, based on the financial and structural indicators of the preceding two financial years.
For further information on the TSRS and its implications for your company’s obligations, please contact your CMS partner or local CMS experts in Corporate Law: Dr. Döne Yalçın, Hülya Kemahlı and Dr. Zeynep Berin Manavgat.
