TSRS 1 and TSRS 2, Turkey's adoption of IFRS S1 and S2, are mandatory for entity types named in the scope decision of the Public Oversight Authority (KGK) once they exceed at least two of three thresholds (total assets TRY 1 billion, net sales TRY 2 billion, 500 employees) in two consecutive financial periods. Banks outside the TMSF are in scope regardless of size. These thresholds apply to financial periods beginning on or after 1 January 2025, newly covered entities get two reporting periods of Scope 3 relief, and the amended TSRS 2 applies from periods beginning 1 January 2027.
If you are a parent company, an investor or an auditor looking at a Turkish subsidiary, three points cause most of the confusion: what happens to large companies that are not on the list, which year the two-period rule actually triggers, and how the Scope 3 relief is counted. We take them in turn.
Who is in scope: entity type first, size second
The legal basis is KGK's decision of 27 December 2023 (Official Gazette 29.12.2023/32414, first duplicate issue). It sets out a list of entity types and applies the size thresholds only to those. The order matters. A family-owned manufacturer with TRY 10 billion in sales that is not on the list applies TSRS voluntarily under article 3(3), however large it is.
| Entity type | Regime | Basis |
|---|---|---|
| Companies whose shares trade on Borsa Istanbul markets (excluding the Watchlist Market and the Venture Capital Market) | Size test | Art. 3(1)(a)(8), as amended by OG 18.12.2024/32756 |
| CMB-regulated institutions: investment firms, collective investment schemes, portfolio managers, central clearing and custody, etc. | Size test | Art. 3(1)(a)(1)-(7) |
| Banks (other than those under the TMSF) | Mandatory, no threshold | Art. 3(2) |
| BRSA-regulated non-banks: leasing, factoring, consumer finance, asset management, etc. | Size test | Art. 3(1)(b)(2)-(9) |
| Insurance, reinsurance and pension companies | Size test | Art. 3(1)(c) |
| Unlisted joint-stock companies issuing non-equity capital market instruments | Voluntary (removed from mandatory scope) | OG 18.12.2024/32756 |
| Everyone else | Voluntary | Art. 3(3) |
A common misreading is "listed means in scope". It does not. A listed company is on the list, but it still has to pass the size test.
Thresholds and the two-period rule
KGK's decision of 13 January 2026 (OG 16.01.2026/33139) doubled the thresholds and tied the new values to financial periods beginning on or after 1 January 2025.
| Criterion | 2024 financial period | 2025 onward |
|---|---|---|
| Total assets | TRY 500 million | TRY 1 billion |
| Annual net sales | TRY 1 billion | TRY 2 billion |
| Employees | 250 | 500 |
At least two of the three must be exceeded in two consecutive periods, and the obligation starts in the following period (art. 4(1)). Figures are consolidated: subsidiaries are added with intra-group transactions eliminated, associates are added pro rata, and headcount follows the same logic (art. 4(4)).
There is an exit rule too (art. 4(2)): fall below at least two thresholds in two consecutive periods, or fall 20% or more below at least two of them in a single period. Exit also takes effect from the next period, so the year in which you drop below still requires a report.
Two practical notes. The decision itself says "exceeding", while the example tables in KGK's implementing Procedures and Principles use "or above". If a figure sits exactly on a threshold, get a written view. Also, OG 33139 is silent on which threshold set applies to 2023 and 2024 when they serve as reference years for the 2025 and 2026 assessments. Companies near the line should run both readings and document the result if they differ.
Worked example
A hypothetical listed company, consolidated figures:
| Period | Total assets | Net sales | Employees | Criteria exceeded |
|---|---|---|---|---|
| 2025 | TRY 1.40 bn | TRY 1.80 bn | 620 | 2 (assets, employees) |
| 2026 | TRY 1.65 bn | TRY 2.30 bn | 640 | 3 |
Two consecutive periods with at least two criteria exceeded, so the company is subject to TSRS from the 2027 financial period. Its 2027 and 2028 reports are its first two reporting periods and Scope 3 is not required in them; Scope 3 comes in with the 2029 report. Because 2027 is also the first mandatory year of the amended TSRS 2, this company will never use the original TSRS 2 text.
Scope 3 relief: who gets it and for how long
Provisional article 3 of the KGK decision does not require Scope 3 GHG disclosure in the first two annual reporting periods in which TSRS is applied. The relief runs on the entity's own sequence, not on the calendar: 2024 and 2025 for a bank that started in 2024, 2027 and 2028 for the company in the example above.
The usual mistake is assuming the relief without documenting which reporting period this is. If the answer to "is this our first, second or third report?" is not on file, an empty Scope 3 line is hard to defend in an assurance engagement.
Smaller BRSA-regulated entities get an extra option. Under OG 18.12.2024/32756, entities in art. 3(1)(b) whose shares are not traded on Borsa Istanbul and that had no more than one branch or no more than 250 employees at the previous year-end may report voluntarily during the periods covered by the Scope 3 relief.
Treat the relief as preparation time. Without a working process for supplier data, procurement spend and logistics records within two years, the third report ends up with spend-based estimates.
The TSRS 2 amendments (Official Gazette 33323)
KGK's decision of 22 July 2026, no. [01/44275], was published in Official Gazette no. 33323 on 28 July 2026. It transposes the ISSB's "Amendments to IFRS S2: Amendments to Greenhouse Gas Emissions Disclosures". KGK's announcement of 30 July 2026 summarises it as follows:
- It clarifies that a competent authority or the exchange on which the entity is listed may require a different measurement method. This jurisdictional relief can be used for part of the entity only (B24, B28).
- A parallel relief covers global warming potentials: if a regulator requires a different GWP set, it can be used instead of the latest IPCC values (B21-B22).
- Scope 3 Category 15 (investments) is reworked. Certain financial activities, such as derivatives, can be excluded from measurement, with the exclusion explained, and new disclosures are added (29A-29C).
- The rules on the industry classification system that commercial banks and insurers use for financed emissions are rewritten.
- Transition provisions are added for the first period of application (C1B, C6).
Effective date: reporting periods beginning on or after 1 January 2027. Early application is permitted but must be disclosed. A calendar-year company prepares its 2026 report under the old text and its 2027 report under the new one.
For industrial companies the practical gain is the method and GWP relief. A plant that already calculates emissions with a method imposed by a competent authority (installations under the Turkish ETS should assess this against their monitoring plans) can carry the same figure into its TSRS report with a reasoned disclosure. The Category 15 changes mainly affect banks, insurers and holding companies with investment portfolios.
How it relates to GRI 102: Climate Change 2025
GRI published GRI 102: Climate Change 2025 in June 2025. It is required for climate reporting published on or after 1 January 2027, when GRI 305 disclosures 305-1 to 305-5 and GRI 201 disclosure 201-2 are withdrawn. Scope 1, 2 and 3 are now reported under 102-5, 102-6 and 102-7, and measurement follows the GHG Protocol Corporate Standard.
| TSRS 2 amendments | GRI 102 | |
|---|---|---|
| Trigger | Reporting period beginning on or after 1 Jan 2027 | Report published on or after 1 Jan 2027 |
| Lens | Financial materiality, investor-facing | Impact materiality, the entity's effect on the climate |
| Legal force | KGK decision | Choice to report in accordance with GRI |
| Extra topics | Category 15, GWP and method relief | Transition plan, adaptation, just transition, removals, carbon credits |
The first row matters in practice. A calendar-year company publishing its 2026 sustainability report in April 2027 must use GRI 102 if it reports in accordance with GRI, while the TSRS section of the same report may still follow the old TSRS 2.
GRI and the IFRS Foundation have published a joint statement confirming that the Scope 1, 2 and 3 disclosures in IFRS S2 can be used to meet the corresponding GRI 102 requirements. Since TSRS 2 is Turkey's adoption of IFRS S2, one inventory can serve both reports. The statement is written for IFRS S2; we found no separate statement naming TSRS, so the content index should anchor the equivalence on IFRS S2.
How Carbolyt handles it
In Carbolyt you enter the entity type and, per period, consolidated assets, sales and headcount. The assessment checks the entity-type gate first, then the threshold set for the period, then the two-period rule, and shows the result with article references. If the reporting period number is missing, Scope 3 relief is not assumed and the result stays "undetermined". When the two threshold readings for borderline companies disagree, the screen says so.
The TSRS tab includes a panel for the 2027 amendments: early-application statement, method and GWP relief, Category 15 limits and the financed-emissions subtotal. The GRI tab produces disclosures 102-5 to 102-8, with their 305 equivalents, from the same frozen calculation. See the platform overview, the source texts on the regulation page, or request a demo with your own figures.
Frequently asked questions
Does every company listed on Borsa Istanbul have to report under TSRS?
No. Listed companies are on the KGK entity list but remain subject to the size test: they must exceed at least two of three thresholds (total assets TRY 1 billion, net sales TRY 2 billion, 500 employees) in two consecutive financial periods. Companies on the Watchlist Market and the Venture Capital Market were removed from mandatory scope in December 2024. Only banks outside the Savings Deposit Insurance Fund (TMSF) are in scope regardless of size.
A company exceeded the thresholds in 2025 and 2026. When does it start reporting?
From the 2027 financial period. Under article 4(1) of the KGK decision, the obligation starts in the period following the two consecutive periods in which the thresholds were exceeded.
How long does the Scope 3 relief last?
Provisional article 3 of the KGK decision exempts Scope 3 disclosure in the first two annual reporting periods in which the entity applies TSRS. The relief follows the entity's own reporting sequence, not the calendar: for a company entering scope in 2027 it covers 2027 and 2028.
When do the TSRS 2 amendments apply?
KGK's decision of 22 July 2026 was published in the Official Gazette no. 33323 on 28 July 2026. The amendments apply to reporting periods beginning on or after 1 January 2027. Early application is permitted and must be disclosed.
Sources
- Official Gazette 16.01.2026/33139: KGK Board Decision 13.01.2026 [01/39092] (TSRS thresholds)
- Official Gazette 28.07.2026/33323: KGK Board Decision 22.07.2026 [01/44275] (TSRS 2 amendments)
- KGK Announcement 2026-31: Amendments to TSRS 2 (30.07.2026)
- GRI 102: Climate Change 2025 – Frequently Asked Questions
- GRI – Topic Standard Project for Climate Change
This article is for information and is not legal advice. Dates and rates reflect the official texts at the time of publication; check the current text before acting.