Your Turkish customer has sent you an ESG questionnaire. Here is what the law requires of them โ and what they need from you.
Turkey has introduced mandatory sustainability reporting for listed companies through the Capital Markets Board (SPK โ Sermaye Piyasasฤฑ Kurulu) and the Borsa Istanbul stock exchange. Turkey is also a candidate country for EU accession and is deeply integrated into European supply chains โ particularly in textiles, automotive, chemicals, and manufacturing. EU buyers subject to CSRD and CSDDD are already applying ESG requirements to their Turkish suppliers, and Turkey's own regulatory framework is converging with EU standards as part of the accession process. If you supply goods or services to a Turkish buyer, or if your Turkish buyer supplies European markets, ESG compliance evidence is increasingly a regulatory and procurement requirement.
Key regulations in Turkey โ ESG & Sustainability Reporting Supplier Guide
Turkish Sustainability Reporting Standards (TSRS) โ IFRS S1 & S2 Aligned
Turkey's Public Oversight, Accounting and Auditing Standards Authority (KGK) published the Turkish Sustainability Reporting Standards (TSRS) in 2023. TSRS 1 covers general sustainability disclosure requirements (aligned with IFRS S1) and TSRS 2 covers climate-related disclosures (aligned with IFRS S2 and EU ESRS). The first TSRS-aligned sustainability reports were due in 2025 covering the 2024 reporting year, for public interest entities meeting at least two of: 250+ employees, TL 1 billion+ annual revenue, or TL 500 million+ total assets. From September 2024, independent assurance audits of sustainability reports became mandatory. Scope expands to more companies from 2026. The Capital Markets Board (CMB) supervises compliance for Borsa Istanbul listed companies.
EU CSRD & CSDDD โ Reach into Turkish Suppliers
Turkey's deep integration into European supply chains means that Turkish suppliers are among the most directly affected by EU CSRD and CSDDD. EU buyers in automotive, textiles, chemicals, and manufacturing are already applying ESG requirements to their Turkish suppliers. As an EU candidate country, Turkey's regulatory framework is converging with EU standards โ Turkish companies that build CSRD-aligned ESG credentials now are better positioned for both current questionnaires and future regulatory requirements.
Turkish Green Deal Action Plan
Turkey has adopted a Green Deal Action Plan aligned with the EU Green Deal. This includes commitments to carbon pricing, renewable energy, and sustainable supply chains. The EU Carbon Border Adjustment Mechanism (CBAM) directly affects Turkish exporters of steel, cement, aluminium, fertilisers, and electricity to the EU โ these sectors face carbon pricing obligations from 2026.
EU Carbon Border Adjustment Mechanism (CBAM)
The EU CBAM requires EU importers of steel, cement, aluminium, fertilisers, electricity, and hydrogen to purchase carbon certificates corresponding to the carbon price that would have been paid under EU carbon pricing rules. Turkey is a major exporter of steel and other CBAM-covered products to the EU. Turkish suppliers in these sectors must be able to provide verified carbon emissions data to their EU buyers.
What this means for you as a supplier
You may not be directly regulated by all of these frameworks. But your Turkish buyer is โ and so are the EU buyers in your supply chain. Borsa Istanbul-listed companies must disclose supply chain sustainability data. EU buyers must assess Turkish suppliers under CSRD and CSDDD. Turkish steel, cement, and aluminium exporters face direct carbon pricing obligations under CBAM. A non-response or a weak response increases your buyer's regulatory risk and makes you a liability in their supply chain.
Key dates
2023
TSRS published โ Turkish Sustainability Reporting Standards (IFRS S1 & S2 aligned) enacted by KGK
September 2024
Mandatory assurance audits โ independent audit of sustainability reports now required for in-scope Turkish companies
2025
First TSRS reports due โ large public interest entities must publish TSRS-aligned sustainability reports covering 2024
Active now
EU CSRD โ large EU companies must disclose supply chain sustainability data including Turkish suppliers
2026
TSRS scope expands to mid-sized firms; EU CBAM full implementation โ Turkish steel, cement, aluminium, and fertiliser exporters face carbon pricing
July 2029
EU CSDDD Phase 1 โ large EU companies must conduct active supply chain due diligence; Turkish suppliers will receive structured questionnaires
Turkey's position as an EU candidate and major European supplier
Turkey is one of the EU's largest trading partners and a major supplier to European manufacturers in automotive, textiles, chemicals, and steel. As an EU candidate country, Turkey's regulatory framework is progressively aligning with EU standards โ including sustainability reporting, carbon pricing, and supply chain due diligence. Turkish companies that build ESG credentials aligned with EU standards are better positioned for both current procurement requirements and the regulatory convergence that EU accession will require.
CBAM โ critical for Turkish steel, cement, and aluminium exporters
Turkey is a major exporter of steel, cement, and aluminium to the EU. The EU Carbon Border Adjustment Mechanism (CBAM) requires EU importers of these products to purchase carbon certificates corresponding to the embedded carbon in imported goods. From 2026, Turkish exporters in these sectors must provide verified carbon emissions data to their EU buyers โ without it, the EU buyer cannot calculate their CBAM obligation and may source from suppliers who can provide the data.
What your Turkish buyer's questionnaire will ask
GHG emissions and carbon data
Scope 1 and Scope 2 emissions data, and increasingly Scope 3 (supply chain) emissions. CBAM-covered sectors (steel, cement, aluminium) must provide verified embedded carbon data. EU CSRD buyers require supply chain emissions data.
Labour rights and working conditions
Compliance with Turkish Labour Law, minimum wage, working hours, health and safety, and freedom of association. EU buyers will reference ILO conventions and their own jurisdiction's supply chain due diligence laws.
Human rights due diligence
A written policy covering forced labour, child labour, and non-discrimination. Evidence that you assess your own supply chain for human rights risks. EU CSDDD buyers require documented human rights due diligence from their Turkish suppliers.
Environmental management
Environmental management systems, waste management, water usage, and energy efficiency. ISO 14001 certification is increasingly expected by EU automotive and manufacturing buyers.
Supply chain traceability
Evidence of your own supplier assessment processes. EU and German buyers require traceability through the supply chain โ not just first-tier supplier compliance.
Governance and anti-corruption
Anti-bribery and anti-corruption policies. Board oversight of ESG matters. International buyers will reference their own jurisdiction's anti-corruption laws and the UN Global Compact principles.
What happens if your response is inadequate
- โYour Borsa Istanbul-listed buyer must disclose supply chain sustainability data โ a non-response from you creates a gap in their mandatory SPK report
- โEU buyers of your steel, cement, or aluminium cannot calculate their CBAM obligation without your verified carbon data โ they may source from suppliers who can provide it
- โEU buyers subject to CSDDD may be required to source from suppliers who can demonstrate compliance โ a non-response puts your contract at risk from July 2029
- โGerman buyers subject to LkSG must assess Turkish suppliers โ weak responses create compliance gaps for your buyer and procurement risk for you
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change โ verify current requirements with a qualified adviser.
Received an ESG questionnaire from your buyer?
ESG Stress Free guides Turkish suppliers through ESG and supply chain compliance requirements from international buyers.