How Türkiye's TSRS rules work as KGK opens a sustainability reporting licence exam

Türkiye's Public Oversight, Accounting and Auditing Standards Authority (KGK) announced on 7 October an exam for the Corporate Sustainability Reporting Expertise (KSRU) licence, to be held in Ankara and Istanbul on 12 December. Applications run from 9 to 30 October, according to announcement 2026-39. The announcement comes as large Turkish companies report under the Turkish Sustainability Reporting Standards (TSRS), which KGK's FAQ page describes as a direct Turkish translation of the standards issued by the International Sustainability Standards Board (ISSB). KGK's homepage also lists the launch of its Reporting Matters Türkiye 2025 report on 29 September and a sustainability reporting experience-sharing meeting on 5 October.

The exam and the licence

The announcement says any holder of a four-year bachelor's degree may apply, whatever the faculty, and that the fee is TRY 1,200. The exam is a single 180-minute multiple-choice session in two modules. Module I carries 100 points, with 15 practical and 40 theoretical questions on TSRS and 30 questions on other topics, including the Turkish Green Deal Action Plan, emissions control and ESG. Module II carries 100 points through 20 questions on financial reporting and corporate governance. Candidates need at least 60 points in each module, and a score stays valid until the end of the third calendar year after the announcement.

Passing does not by itself confer the licence. Candidates must also meet other conditions in Article 5 of the procedures and principles for the licence, which were published in the Official Gazette on 1 October 2025, the announcement says. It does not describe what a KSRU holder may do or whether the licence is an assurance qualification.

Who must report under TSRS

According to KGK's FAQ, a company is in mandatory scope if it belongs to the public-interest company types listed in Article 3(1) of the KGK Board Decision and exceeds at least two of three thresholds in two consecutive reporting periods: total assets of TRY 500 million, annual net sales of TRY 1 billion, or 250 employees. Banks regulated under Banking Law No. 5411 are in scope whatever their size, except those within the Savings Deposit Insurance Fund, which are exempt. Group figures combine parent and subsidiaries with intra-group transactions eliminated, and associates count in proportion to the shareholding. A company leaves scope from the following accounting period if it falls below at least two of the thresholds in two consecutive periods, or 20 per cent or more below them in a single period. Companies outside scope may report voluntarily.

Mandatory reporting applies to the financial period beginning on 1 January 2024, with that year's activity reported during 2025, the FAQ says. In the first two annual reporting periods under TSRS, companies do not have to disclose Scope 3 greenhouse gas emissions. Reports must cover governance, strategy, risk management, and metrics and targets. They should be made at the same time as, and for the same period as, the financial statements, with a first-year allowance to publish afterwards. Companies with interim reporting duties may submit with their second-quarter or six-month interim financial reports, and others have nine months from the end of the reporting period, according to the FAQ.

Reports on the 2024 financial year are subject to mandatory sustainability assurance, the FAQ says. Until GDS 5000, a standard aligned with ISSA 5000 that is planned but not yet published, GDS 3000 and GDS 3410 remain in use. KGK says it will authorise assurance providers from among independent auditors who pass a separate sustainability auditing exam.

How it relates to EU rules

The FAQ does not explain how TSRS relates legally to the EU's Corporate Sustainability Reporting Directive (CSRD) or the European Sustainability Reporting Standards (ESRS). It does list the connection between TSRS and the CSRD, the ESRS, the Carbon Border Adjustment Mechanism (CBAM) and the EU emissions trading system among the Module I topics for the KSRU exam, under the heading of the Turkish Green Deal Action Plan. The same list names the emissions trading system and CBAM as separate topics.

The EU's own reach over non-EU groups is set by Directive (EU) 2026/470. Its amended Article 40a applies only where a third-country group generated net turnover in the Union above EUR 450 million in each of the last two consecutive financial years, and then to EU subsidiaries or branches with net turnover above EUR 200 million. Recital 26 says the group-level figure was raised from EUR 150 million. A third-country group below the group-level test therefore falls outside that article.