Replacing the NFRD, the CSRD broadens sustainability reporting in both scope and depth. Reports are prepared according to the double materiality principle and undergo limited assurance. Because EU clients must report value-chain data, these demands flow down to Turkish suppliers through contracts and questionnaires.
Overview
The Corporate Sustainability Reporting Directive (CSRD) transforms sustainability reporting in the EU from a voluntary and fragmented practice into a standardised and audited obligation. Reports are prepared in accordance with the European Sustainability Reporting Standards (ESRS) and published as part of the company’s management report.
In Türkiye the directive bites indirectly but hard: EU customers within scope must report on their own value chains, so they ask their suppliers for emissions, energy, occupational health and human rights data.
Scope and phased timeline
The scope widens in waves according to thresholds for balance-sheet size, net turnover and employee count. The first reports were published for the 2024 financial year by large listed companies that were previously within the scope of the NFRD. The later waves were pushed back by two years by the postponement (“stop-the-clock”) directive adopted in April 2025. The Omnibus I directive adopted in February 2026 ((EU) 2026/470) then narrowed the scope to undertakings with >1,000 employees and >€450 million net turnover (for third-country groups, €450 million of EU turnover). The new thresholds apply to financial years beginning on or after 1 January 2027.
Critical point for the Turkish side
A slipping timetable does not stop the data requests: large customers are already collecting supplier data through contracts and annual surveys. The supplier that is ready holds the advantage in the commercial relationship.
Key obligations
A company within scope carries out a double materiality analysis and, on that basis, discloses its strategy, targets, policies and performance indicators, reports the material impacts across its value chain, and obtains limited assurance on the report. The disclosures are digitally tagged and public.
Impact on Turkish companies
Turkish suppliers feel the CSRD through three channels: customer requests for data and commitments, sustainability clauses arriving in contracts, and ESG assessment in tender and onboarding processes. Turkish groups with significant turnover and subsidiaries in the EU may, at a later stage, become directly subject to reporting obligations.
Roadmap
We recommend working in this order: take an inventory of customer requests and contract clauses; establish which data the business already produces; assign responsibility for collecting the rest; and build a single common file alongside the LkSG and CSDDD compliance work. That avoids duplicated effort and leaves an audit-ready structure behind.
Sanctions and de facto pressure
The CSRD prescribes no uniform fine at EU level; sanctions sit in each member state’s accounting and transparency law. In practice the real pressure comes from the market: the auditor’s opinion, access to financing, tenders and customer assessments. For a supplier the sanction is contractual — one that cannot provide the data comes off the list.
Related content
Read this entry together with the LkSG and CSDDD entries; for compliance strategy, our ESG & Sustainability focus area and our CSDDD analysis offer guidance.
