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Legal Alerts

TSRS Scope Update: Sustainability Reporting Thresholds Increased

Legal Alerts
Corporate
General

Recent Development

The decision (“Decision“) of the Board of the Public Oversight, Accounting and Auditing Standards Authority (POA), revising the threshold criteria used to determine the scope of application of the Türkiye Sustainability Reporting Standards (TSRS), was published in the Official Gazette on 16 January 2026. The Decision entered into force and will apply to financial reporting periods beginning on or after 1 January 2025.

You can access the Decision here.

What’s New?

The Decision introduces amendments to the threshold values set out in the Board Decision on the Scope of Application of the TSRS, which was published in the Official Gazette on 29 December 2023 and determines the companies required to conduct sustainability reporting under the TSRS. Other than the changes in the threshold values, the categories of companies subject to TSRS sustainability reporting remain unchanged.

Compared to the current framework, the threshold values applicable to companies subject to TSRS have been increased as follows:

Company typePrevious thresholdsNew thresholds
(effective as of 1 January 2025)
All banks, except those under the Savings Deposit Insurance Fund (SDIF)All banks, except those under the SDIF, are required to prepare sustainability reports under the TSRS without being subject to any thresholds.
  1. Investment institutions
  2. Collective investment institutions
  3. Portfolio management companies
  4. Mortgage finance companies
  5. Central clearing organizations
  6. Central securities depositories
  7. Trade repositories
  8. Joint stock companies whose capital market instruments are traded on a stock exchange or other organized markets, or that have a prospectus (izahname) or issuance certificate (ihraç belgesi) that has not expired
  9. Joint stock companies issuing non-share capital market instruments through private placement, not to be publicly traded (until the end of the accounting period in which these capital market instruments are redeemed), and joint stock companies with an issuance certificate for this purpose that has not expired
  10. Rating agencies
  11. Financial holding companies
  12. Financial leasing companies
  13. Factoring companies
  14. Financing companies
  15. Asset management companies
  16. Companies with qualified shares in financial holding companies and banks
  17. Savings finance companies
  18. Insurance, reinsurance and pension companies
  19. Precious metals intermediary institutions, and companies engaged in the production or trade of precious metals and other authorized institutions in the Borsa Istanbul markets
Entities exceeding at least two of the following thresholds (assessed together with their subsidiaries and affiliates) for two consecutive reporting periods:

  • Total assets of TRY 500 million
  • Annual net sales revenue of TRY 1 billion
  • 250 employees

 

Entities exceeding at least two of the following thresholds (assessed together with their subsidiaries and affiliates) for two consecutive reporting periods:

  • Total assets of TRY 1 billion
  • Annual net sales revenue of TRY 2 billion
  • 500 employees

 

Conclusion

The Decision entered into force and applies to financial reporting periods beginning on or after 1 January 2025. Companies should therefore reassess their status under the newly increased thresholds to determine whether they fall within the scope of the TSRS sustainability reporting. For companies that meet the revised criteria, timely preparation and implementation of necessary reporting procedures will be essential.