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The TSRS supply chain reporting obligation is no longer a matter of reputation, but a legal requirement. The 2026 independent assurance period of the Turkish Sustainability Reporting Standards (TSRS) has effectively begun. However, most supply chain executives miss a critical fact: you cannot present this report to the auditor without obtaining data from your suppliers.
In this article, we address step by step why TSRS places the supply chain at the center, what companies listed on Borsa Istanbul demand from their suppliers today, and why compliance cannot be achieved without a digital supply chain platform.
What Is TSRS and Which Companies Does It Cover?
TSRS refers to the Turkish Sustainability Reporting Standards published by the Public Oversight, Accounting and Auditing Standards Authority (KGK) based on IFRS S1 and S2. The standards were published in the Official Gazette dated 5 September 2024, and the reporting obligation began with the 1 January 2025 accounting periods.
Scope is entered through two paths. First, entities directly included regardless of size criteria: banks subject to the BRSA (BDDK), publicly traded companies under the CMB (SPK), and insurance and financial services companies. Second, enterprises falling within the scope based on size criteria. The KGK updated threshold values with the Official Gazette decision dated 16 January 2026:
- Total assets: 1 billion TL and above
- Annual net sales revenue: 2 billion TL and above
- Number of employees: 500 and above
Enterprises exceeding at least two of these three criteria in two consecutive accounting periods become subject to TSRS. Note that threshold values doubled in January 2026: the initial values announced at the end of 2023 were 500 million TL assets, 1 billion TL sales, and 250 employees. Since the KGK can update these figures, perform scope evaluations with fresh data before each reporting period.
Critical Difference Between 2025 and 2026: The Assurance Period
The fundamental difference between the two years is the audit obligation. In 2025, in-scope companies publish their first TSRS reports; these reports cover Scope 1 and Scope 2 greenhouse gas emission calculations within the framework of TSRS 2. 2026 is the independent assurance period: reports now undergo independent auditor examination.
Auditors authorized by the KGK examine the report within the framework of GDS 3000 and GDS 3410 standards. In this audit, it is necessary to show that every disclosed piece of data is based on evidence. Statements such as "according to our estimates" or "based on industry averages" are no longer sufficient. Every line, including emission data coming from the supply chain, must be supported by a traceable and auditable source document.
Why Is the Supply Chain So Central to TSRS?
TSRS 2 mandates the disclosure of climate-related risks. This disclosure covers not only the smoke coming from your factory chimney, but your entire supply chain. Scope 1 emissions originate from sources you control directly (factory, vehicle fleet), Scope 2 from the energy you purchase, and Scope 3 from suppliers, logistics, and the product lifecycle.
Globally, seventy-six percent of companies report at least one Scope 3 category; however, this rate lags twelve percentage points behind Scope 1-2 reporting. Why? Collecting Scope 3 data requires coordination with hundreds of suppliers outside direct control.
Although Scope 3 disclosure is not mandatory in the first two reporting periods, TSRS 2 requires identifying and managing supply chain risks. Establishing this risk profile without receiving any data from suppliers is like giving directions with a blank map.
Real Picture from Turkey: What Do BIST Companies Want?
Companies that wish to be included in the Borsa Istanbul Sustainability Index or are already included share sustainability data with the public via the LSEG ESG Contributor Tool. Many of these companies now reflect this obligation in their supply chain contracts as well.
In practice, the picture takes shape as follows: A large BIST company requests carbon emission data, energy consumption documents, and supplier compliance surveys during the new supplier onboarding process. SME suppliers unable to respond to this request are eliminated during the contract renewal process or are forced to revise their working conditions according to tightened ESG criteria. For Turkish suppliers exporting to the EU, the pressure is two-way: European buyers report their supply chains under the CSRD; the main customer in Turkey also collects supplier data pursuant to TSRS.
Without a digital supply chain management platform, this data flow becomes operationally unsustainable.
Why Can't It Be Passed with Manual Methods?
Most supply chain managers ask the same question: "Can't we succeed with spreadsheets?" The short answer: You can start, but you cannot pass the independent assurance audit. Three fundamental reasons explain this.
First is the scale problem. Collecting periodic emission, energy consumption, and compliance data from a supplier list of hundreds of rows creates a disproportionate workload with manual methods. Emailing every supplier, entering responses one by one, and checking consistency multiplies employee-hour costs.
Second is the absence of an audit trail. The independent assurance auditor looks not only at the result, but at how the data was collected, when it was updated, and by whom it was approved. Spreadsheets cannot provide this trail by nature; in an environment where manual entries are overwritten, deletion records are absent, and version history is inconsistent, the auditor does not provide assurance.
Third is the supplier data maturity problem. A significant portion of SMEs acting as suppliers to large companies do not yet measure their carbon footprint. When data does not come from these suppliers, the company remains condemned to sectoral averages; estimated values are not numbers to which an auditor provides assurance.
What Digital Supply Chain Platforms Provide
Digital supply chain management platforms structurally solve these three problems. To meet TSRS supply chain reporting requirements, three key functions of the platform stand out.
Data reliability and audit trail: Automated data collection stores every entry with a timestamp and user record. This record directly meets the evidence infrastructure sought by audits within the framework of GDS 3000.
Scalability: Invoice data, distance information, and energy consumption from hundreds of suppliers can be pulled instantaneously. Moving away from the annual reporting cycle allows continuous monitoring; working with quarterly updates instead of year-end congestion becomes possible.
Supplier capacity building: Well-designed platforms also offer an entry interface to suppliers. An SME supplier that has not measured its carbon footprint enters its own data guided through the platform. This approach reduces the use of estimated values and increases the likelihood of the report passing independent assurance.
For companies operating with EDI integration and B2B e-commerce infrastructure, this integration is particularly valuable. Supplier orders, invoice flows, and logistics data are already flowing in the digital environment; the raw material required for Scope 3 calculation is largely available. The only thing that needs to be done is to link these data flows with the emission calculation engine. You can check here to access the KGK's current TSRS guidance publications.
Conclusion: Building Data Infrastructure Can No Longer Be Postponed
TSRS 2026 transforms sustainability reporting from a process of intention into a process of evidence. A report prepared without supply chain data is either declared incomplete in the independent assurance audit or receives a qualified assurance opinion. In either case, legal risk increases, supplier relations are damaged, and access to the EU market becomes more difficult.
Three concrete steps stand out. First, verify whether you fall under TSRS based on current threshold values with two accounting periods of data. Second, map your supplier data collection process and identify which suppliers cannot provide emission data. Third, question whether your existing supply chain management infrastructure provides an audit trail suitable for independent assurance audits.
Digital supply chain platforms provide structural support in all three steps. Preparing an ESG report without supply chain data is like putting a roof on a building whose foundation has not been poured. Lack of infrastructure cannot hold up during the assurance phase, no matter how well written the report is.
You can visit the MAP Blog page for more content on supply chain digital transformation and TSRS compliance processes.
Frequently Asked Questions (FAQ)
Which companies are required to comply with TSRS?
Banks subject to the BDDK and publicly traded companies within the scope of the SPK are subject to TSRS regardless of their size. For other enterprises, the current threshold values are as follows: total assets of 1 billion TL, annual net sales revenue of 2 billion TL, and 500 employees. Enterprises exceeding at least two of these three criteria in two consecutive accounting periods fall within the scope.
What does independent assurance mean for TSRS in 2026?
The first reports will be published in 2025; as of 2026, these reports will be subject to assurance audits by independent auditors authorized by the KGK. The audit is conducted in accordance with the GDS 3000 and GDS 3410 standards. Assurance requires the report to be based on evidence-based data, not merely on declarations.
Why is supply chain data critical for TSRS?
Climate-related risks and opportunities must be disclosed under TSRS 2. Scope 3 emissions originating from suppliers exceed seventy percent of the total carbon footprint in many sectors. Without this data, the report cannot be completed; the independent auditor cannot provide assurance.
What happens without Scope 3 emission data?
The assurance auditor removes unprovable emission values from the report or issues a qualified assurance report. This situation weakens the report legally, increases the risk of being removed from supplier lists, and threatens commercial relationships with EU customers.
How does a digital supply chain platform facilitate TSRS compliance?
Digital platforms automatically collect supplier data, create an audit trail, and provide the evidence infrastructure required by TSRS 2. Pulling instant data from hundreds of suppliers is practically impossible with a manual spreadsheet method.
Sources
- KGK — Board Decision on TSRS Scope of Application (Official Gazette, 5 September 2024)
- KGK — Board Decision on Redetermination of Threshold Values (Official Gazette, 16 January 2026, Issue 33139)
- Greenix — TSRS Scope Criteria and Threshold Values
- Life Climate — The Importance of Digital Solutions in Scope 3 Emission Reporting
- Kaan Şafak Law Firm — Sustainability Reporting Obligation for Companies: TSRS 2026 Assurance Period and Legal Obligations
- Escarus — Turkish Sustainability Reporting Standards
