Publised on Aug 25, 2026
Gamoda
In January 2026 the thresholds were doubled. For many companies this looked like good news — but the consequences are less straightforward than they appear. Some companies that were in scope last year are out of scope this year; falling out of scope, however, does not mean the need to prepare sustainability data has gone away.
This post answers three questions in order: are you in scope, from when, and if you are not, what does that mean for you.
First: those in scope regardless of size
Some entities are covered whatever their size. Check this list before running any threshold calculation:
Banks, other than those within the Savings Deposit Insurance Fund
Investment institutions
Insurance and pension companies
Companies traded on capital markets
If you are in this group, the threshold calculation below does not concern you — go straight to the timetable. The full list is set out in the KGK Board Decision on the scope of application.
Three thresholds, two conditions
For everyone else, the rule works as follows. There are three criteria:
| New threshold | Previous threshold |
Total assets | TRY 1 billion | TRY 500 million |
Annual net sales revenue | TRY 2 billion | TRY 1 billion |
Number of employees | 500 | 250 |
Both conditions must be met together:
First: you must exceed at least two of the three criteria. All three is not required; one is not enough.
Second: you must have done so in two consecutive reporting periods. A single year's figures do not bring you into scope.
What changed in January 2026?
The new thresholds were set by a Board Decision published in the Official Gazette on 16 January 2026 and apply to accounting periods beginning on or after 1 January 2025. The practical effect is more complicated than it first appears.
The previous thresholds applied to the 2024 accounting period. So a company with TRY 600 million in total assets and 300 employees was in scope for 2024 — and is out of scope for the 2025 period.
Three things matter for those companies. Falling out of scope does not erase your obligation for the earlier period. Second, the thresholds are set in Turkish lira, and inflation may bring you back into scope within a few years, so shelving your preparation entirely would be a mistake. Third, and most importantly, being out of scope does not mean your customers will stop asking you for data.
If you are in scope: timetable and transition reliefs
The standards were published in the Official Gazette (repeated issue) of 29 December 2023, and application is being phased in. Three reliefs apply in the early years:
Comparative information is not required. Your first report does not need to include the previous year's figures.
A separate publication window. The sustainability report does not have to be published at the same time as your financial statements; you have up to nine months afterwards.
Scope 3 emissions are exempt for the first two years. You are not required to report value chain emissions in the first two years. This buys time on the hardest part of the preparation — but the relief is time-limited, so the period is best spent building the data infrastructure.
At the same time, the assurance period is beginning: reports will be subject to independent limited assurance, with a move to reasonable assurance expected later. In practice this means your statements need documents and a calculation trail behind them.
A note from our practiceThe most common mistake we see in scope calculations is assessing only the parent company and leaving out the revenue and headcount of its subsidiaries. An incomplete calculation misleads in both directions: a company may believe it is out of scope when it is in fact obliged to report, or it may place the start of its obligation a period later than it actually falls. The only reliable way to answer the scope question is to run the calculation across the group as a whole. |
If you are out of scope
Being out of scope is a relief, but not a settled position. Three things still bring you closer to reporting:
Customer requests. Your European buyers will ask you for data to meet their own obligations. That request operates independently of your TSRS status.
Financing. Lenders and investors have begun using sustainability data in credit and investment decisions.
Growth. You enter scope the moment you exceed the thresholds in two consecutive periods — and at that point you will not want to be collecting two years of data retrospectively.
Companies outside the mandatory scope may also apply the standards voluntarily. A full report is not necessary; beginning to collect data now is usually enough.
In summary
Check first whether you belong to one of the groups covered regardless of size.
If not, calculate the three criteria for the last two periods, including your subsidiaries.
If you exceeded two of the three in two consecutive periods, you are in scope.
If you are in scope, use the first-year reliefs — but remember the Scope 3 exemption is time-limited.
If you are out of scope, assess customer and financing driven requests separately.
If you are unsure about your scope calculation, or want to establish what the result means for you, get in touch — CHON carries out scope assessments.
This post reflects the regulations in force as at 25 August 2026. Thresholds and obligations are subject to change.
